Johnson v. Southern Pacific Co.

Southern Pacific Co. (railroad) (defendant) operated passenger trains that ran between San Francisco and Ogden, Utah. The trains on this route included a dining car, which was attached to a train leaving San Francisco and taken to Ogden. The car was then detached from the train, turned around, and attached to a train traveling back to San Francisco. On August 5, 1900, one of the eastbound trains ran late, making it impossible to get the dining car to Ogden in time to attach it to the intended westbound train. The dining car was left on a side track in another town in Utah so that the westbound train could stop and pick it up on its way to San Francisco. Johnson (plaintiff), the head brakeman on the westbound train, was instructed to couple the train’s engine to the dining car. The engine and the dining car had incompatible automatic couplers, requiring Johnson to manually couple them. As he did so, Johnson’s hand was crushed and was later amputated. Johnson sued the railroad for personal injury. The trial court directed a verdict for the railroad, reasoning that Johnson had assumed the risk of injury. Johnson appealed, arguing that the railroad’s failure to outfit the engine and the dining car with compatible automatic couplers was a violation of federal law and therefore shifted liability for Johnson’s injuries to the railroad. The federal statute enacted to improve railroad safety required locomotive engines used in moving interstate traffic to have power brakes and required train cars used in moving interstate traffic to have automatic couplers. Railroads were assessed a $100 fine for each violation of the statute.