Second Employers’ Liability Cases—Mondou v. New York, New Haven & Hartford Railroad Co.
United States Supreme Court
223 U.S. 1 (1912)
- Written by Steven Pacht, JD
Facts
The Federal Employers’ Liability Act of 1908 imposed liability on railroads for certain work-related injuries that employees suffered due to the negligence of the railroad or a railroad employee. Several challenges were brought against the validity of the act, including one in Connecticut state court in a case brought by Mondou (plaintiff) against the New York, New Haven & Hartford Railroad Company (railroad) (defendant). The Connecticut Supreme Court of Errors ruled that although the state’s superior courts had jurisdiction over personal-injury and wrongful-death cases, including in cases arising under the law of another state and in circumstances under which Connecticut law did not impose liability, (1) Congress implicitly required that a suit under the act be brought only in federal court and (2) even if a suit under the act could be brought in state court, Connecticut’s courts could decline to hear such a suit if the act’s policy conflicted with Connecticut’s policy or if the court believed that it would be confusing or inconvenient to apply federal law. Mondou appealed.
Rule of Law
Issue
Holding and Reasoning (Van Devanter, J.)
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