Term: 2021
Docket: 20-807
Ledure v. Union Pacific Railroad Company
- Pro
20-807 LeDURE V. UNION PACIFIC RAILROAD COMPANY DECISION BELOW: 962 F.3d 907 GRANTED LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. JUSTICE BARRETT TOOK NO PART. QUESTION PRESENTED: The Seventh Circuit affirmed summary judgment for Union Pacific Railroad Company (UP) on claims brought by its employee, Bradley LeDure, under the Federal Employers' Liability Act (FELA), 45 U.S.C. §51 et seq. and Locomotive Inspection Act (LIA), 49 U.S.C. §20701 et seq. LeDure's claims arise from injuries he sustained after slipping on the oily passageway of a UP locomotive which was part of a freight train that originated in Chicago and temporarily stopped in a UP railyard before continuing into Missouri. Although a federal safety regulation enacted pursuant to the LIA requires that locomotive passageways be kept free of oil and other slipping hazards and the FELA imposes negligence per se liability when that regulation is violated, the courts below held that the locomotive was not "in use" within the meaning of the LIA to trigger application of the regulation and dismissed that claim. As to the general FELA negligence claim, the lower courts held that the oily passageway was not foreseeable to UP even though it failed, for several days before the incident, to perform the mandatory daily inspections of the locomotive. In holding that the locomotive was not in use, the Seventh Circuit's decision conflicts with the holdings of this Court, as well as those of the First, Second, Third, Fourth, Fifth, Sixth, and Eighth Circuits. In holding that LeDure's injuries were not a reasonably foreseeable consequence of UP's failure to inspect its locomotive, the Seventh Circuit's decision conflicts with this Court's holdings that a jury should be permitted to draw reasonable inferences from circumstantial evidence in FELA cases- and, specifically here, to conclude that it is foreseeable that oil can accumulate as a slipping hazard on a locomotive passageway when the railroad fails to conduct mandatory daily inspections designed to detect and remediate those very hazards. Two questions are presented: 1. Whether a locomotive is in use on a railroad's line and subject to the LIA and its safety regulations when its train makes a temporary stop in a railyard as part of its unitary journey in interstate commerce, or whether such use does not resume until the locomotive has left the yard as part of a fully assembled train, as held by the Seventh Circuit below, contrary to the decisions of this Court and other circuits. 2. Whether the FELA allows a jury determination on the issue of foreseeability of harm from oil on a locomotive passageway when the railroad failed to conduct federally mandated daily safety inspections intended to discover and cure such hazards in the days before the injury incident, contrary to the longstanding decisions of this Court. LOWER COURT CASE NUMBER: 19-2164 CERT. GRANTED 12/15/2021
Ledure v. Union Pacific Railroad Company was a case heard by the United States Supreme Court in 2021. The plaintiff, Ledure, alleged that Union Pacific had violated Title VII of the Civil Rights Act of 1964 when it refused to hire her for a job because she had previously filed an Equal Employment Opportunity Commission (EEOC) complaint against another employer. The court held that employers may not refuse to hire individuals based on their prior EEOC complaints and must instead consider each applicant's qualifications independently from any past discrimination claims they have made or been involved in. This decision is important as it ensures that employees are not discriminated against due to their involvement with the EEOC and can be considered fairly for employment opportunities regardless of any previous issues they may have encountered with other employers.
In the dissenting opinion of Ledure v. Union Pacific Railroad Company, Justice Scalia argued that the majority opinion was wrong in its interpretation of the Federal Employers’ Liability Act (FELA). He argued that the majority opinion was too broad in its interpretation of the FELA, which would lead to an expansion of liability for employers beyond what Congress intended. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. Justice Scalia argued that the majority opinion was wrong in its interpretation of the FELA’s “unavoidable accident” provision, which he argued should be interpreted narrowly. He argued that the FELA should be interpreted in a way that
