Case Update - Employer Negligence Standard under Federal Employees' Liability Act


Page v. Amtrak, 200 Md. App. 463 (Md. Ct. Spec. App. 2011) [09/02/2011]

This case involves the Federal Employees Liability ACT (FELA) meant to compensate injured railroad workers. The Claimant filed for compensation after a work-related injury. The Circuit Court granted summary judgment for Amtrak and the Claimant appealed. The issue was whether the Circuit Court erred in granting summary judgment on the basis that the Claimant presented no evidence that Amtrak breached any duty to him and that any negligence on Amtrak's part was not the proximate cause of Claimant's injuries. The Court concluded that Claimant's evidence, though circumstantial, would allow a fact finder to infer that Amtrak was negligent and that injury was a foreseeable result thereof. Proximate cause is proven, under FELA, by a demonstration that "employer negligence played any part, even the slightest, in producing the injury." The Court found the Claimant met this threshold. The Claimant injured himself when dropping down (about 4-5 feet) onto a platform to remove a cart that was obstructing the track. The claim of negligence arose of out Amtrak's alleged failure to provide a safe work environment. The fact that these carts end up on the tracks about 3-4 times per year was sufficient to establish that Amtrak could have foreseen the possibility of harm. The Court also stated that an examination of proximate causation plays no role in determining whether a railroad is liable for an employee's injuries.