Johnson v. Southern Pacific Co.

Southern Pacific Company (Southern) (defendant) operated passenger trains between San Francisco and Ogden, Utah. Dining cars were attached to eastbound trains, detached in Ogden, turned around, and attached to westbound trains. A dining car was left on a side track when an eastbound train was running too late for the car to be attached to the next westbound train in Ogden. W. O. Johnson (plaintiff), a freight-train brakeman, was told to couple the train’s engine to the dining car and turn the car around. The engine and dining car had incompatible couplers, requiring Johnson to make the coupling manually. Johnson’s hand was caught and crushed during his third coupling attempt, requiring amputation. Johnson sued Southern for damages. The trial court found that Johnson had assumed the risk of injury and directed a verdict for Southern. On appeal, Johnson argued that Southern’s failure to equip the cars with compatible couplers as required by the Safety Appliance Act (SAA) relieved him of assumption of risk. The SAA required power brakes on locomotives and automatic couplers on cars used in moving interstate traffic. Affirming, the Eighth Circuit held that (1) the locomotive had a power brake and the dining car a coupler, and therefore both were equipped as required; (2) a locomotive was not a car; (3) the dining car was not being used in moving interstate traffic when the accident occurred; and (4) if the automatic-coupler requirement applied to locomotives, the locomotive and dining car both had automatic couplers. The United States Supreme Court granted Johnson’s petitions for writs of certiorari and error.