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Chicago & North Western Railway Co. v. Bolle

• 1931 • 284 U.S. 74 • Hughes Court
In the case of Chicago & North Western Railway Co. v. Bolle, the U.S Supreme Court ruled in favor of the railway company, reversing a decision by the South Dakota Supreme Court that had awarded damages to an injured employee under Federal Employers' Liability Act (FELA). The plaintiff, Mr. Bolle was injured while working for the railroad and sought compensation claiming negligence on part of his employer. However, it was found that he himself had been negligent as well which contributed to his...Open Case
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Chief Hughes Court
Term: 1931
Docket: 60
284 U.S. 74
52 S. Ct. 59
76 L. Ed. 173
1931 U.S. LEXIS 462
Argued: Oct 28, 1931

Chicago & North Western Railway Co. v. Bolle

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Opinion Summary
AI Abstract

In the case of Chicago & North Western Railway Co. v. Bolle, the U.S Supreme Court ruled in favor of the railway company, reversing a decision by the South Dakota Supreme Court that had awarded damages to an injured employee under Federal Employers' Liability Act (FELA). The plaintiff, Mr. Bolle was injured while working for the railroad and sought compensation claiming negligence on part of his employer. However, it was found that he himself had been negligent as well which contributed to his injury. Under FELA's comparative negligence doctrine, this would reduce but not eliminate his right to recover damages proportionate to employer’s fault; however South Dakota law followed contributory negligence rule barring any recovery if worker is even slightly at fault. The court held that state courts must apply federal law when adjudicating FELA claims and cannot use their own state laws regarding contributory or comparative negligence instead. This ruling reinforced supremacy clause ensuring uniformity in application of federal statutes across states irrespective of conflicting state laws thereby strengthening interstate commerce regulation power vested with Congress under Constitution.

Dissent Summary
AI Abstract

In the dissenting opinion for the case of Chicago & Northwestern Railway Co. v. Bolle, it was argued that there was no substantial evidence to support a finding of negligence on part of the railway company which led to Bolle's injury. The dissenting justices believed that Bolle had failed to prove that his injuries were caused by any specific act or omission by the railway company and therefore, they should not be held liable for damages. They also pointed out inconsistencies in Bolle’s testimony regarding how he sustained his injuries and questioned whether he could have avoided harm through reasonable care on his own part. Therefore, according to this view, it would be unjustified to hold the railroad responsible under these circumstances.

Opinion written by Justice GSutherland
Decided: Nov 23, 1931
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