Atchison, T. & S. F. R. Co. v. Buell

480 U. S. 557

March 24, 1987

One federal statute, FELA, required railroads to compensate employees who were injured on the job. Another federal statute, RLA, provides for settlement of railroad labor disputes before an arbitration board. Buell, who had been working on the railroad all the livelong day, suffered a nervous breakdown due to emotional bullying from his boss. He then filed a FELA action to recover damages. In response, the railroad argued that the matter should more properly go before an RLA arbitration board, and that the FELA action was preempted for that reason.

Stevens, writing for a unanimous Court, found no evidence at all in the statutory text or legislative history that RLA arbitration was intended to preempt FELA actions. He also rejected the argument that emotional injury ought to be the exclusive domain of arbitration, saying that such a decision would amount to judicial legislation. Finally, Stevens remanded the case for a determination of whether the FELA’s reach extended to emotional injury. Legally, this looks like the right decision, but that being the case the laws ought to be amended, because I don’t think a railroad should be liable twice for the same basic complaint.


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