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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Goldwater v. Metro-North Commuter Railroad

Elaine Goldwater, an administrative assistant for Metro-North Commuter Railroad, filed suit under the Federal Employers' Liability Act (FELA) and state negligence law after being assaulted at a Metro-North station while traveling to an off-site meeting. Metro-North moved for summary judgment, arguing the "commuter rule" barred the FELA claim and that it owed no duty to protect Goldwater from third-party criminal acts under state law. The court granted summary judgment, determining Goldwater's commute did not fall under any FELA "commuter rule" exceptions as she was not compensated for travel, on-call, or compelled to use Metro-North's trains. Additionally, the court found Metro-North, as a quasi-governmental entity, did not have a special relationship with Goldwater, thus owing her no special duty of protection beyond that owed to the general commuting public for the alleged negligence in station design and maintenance.

Federal Employers' Liability Act (FELA)Commuter Rule ExceptionSummary Judgment MotionThird-Party AssaultRailroad NegligenceGovernmental Entity DutySpecial Relationship DoctrineScope of EmploymentPremises LiabilityEmployee Injury
References
24
Case No. MISSING
Regular Panel Decision
Apr 02, 1997

Robinson v. Metro-North Commuter Railroad

Plaintiffs, 25 current or former Metro-North employees, filed two class action lawsuits alleging employment discrimination based on race under Title VII of the Civil Rights Act of 1964 and various New York State laws against Metro-North Commuter Railroad. They sought class certification for "all African-American employees of defendant Metro-North Commuter Railroad from 1983 through 1996." The Court consolidated the two actions but subsequently denied the motion for class certification. The denial was based on the plaintiffs' failure to satisfy the commonality and typicality requirements of Federal Rule of Civil Procedure 23(a). The Court found that the plaintiffs' statistical data and sociological opinion were insufficient to establish company-wide discriminatory practices, and individual claims varied significantly, thus lacking typicality for such a broad class.

Employment DiscriminationRace DiscriminationClass ActionClass Certification DenialFederal Rules of Civil Procedure 23Commonality RequirementTypicality RequirementStatistical EvidenceSociological OpinionTitle VII
References
19
Case No. MISSING
Regular Panel Decision

Barbanti v. MTA Metro North Commuter Railroad

Plaintiff Robert Barbanti, formerly an Electronic Specialist at Norfolk Southern Railroad, claims he was fraudulently induced by MTA Metro-North Commuter Railroad (Defendant) to leave his job for a supervisory Signal Inspector position with specific pay. Despite being initially hired as a Signal Inspector, a collective bargaining agreement and a subsequent letter agreement with Local 166 led to him being placed in a lower-paying Electronic Technician role. Barbanti sued for fraudulent inducement, breach of contract, and negligent/reckless misrepresentation in state court, a case which the Defendant removed to federal court arguing preemption by the Railway Labor Act (RLA). The court ruled that Barbanti's state law claims are not preempted by the RLA because their resolution does not require the interpretation of a collective bargaining agreement, as the rights and obligations at issue exist independently of any such agreement. Consequently, the court granted Plaintiff's motion to remand the case to state court and denied Defendant's cross-motion for judgment on the pleadings.

Railway Labor ActPreemptionFraudulent InducementBreach of ContractNegligent MisrepresentationCollective Bargaining AgreementLabor DisputesFederal JurisdictionState Law ClaimsMotion to Remand
References
13
Case No. 866 F.Supp.2d 196
Regular Panel Decision
Nov 07, 2011

Howard v. MTA Metro-North Commuter Railroad

Wendell Howard, an African-American locomotive engineer trainee, sued his former employer, MTA Metro-North Commuter Railroad, for racial discrimination and harassment under Title VII and 42 U.S.C. § 1981, following his termination from a training program. Howard alleged discriminatory treatment by his instructors regarding test answers and derogatory remarks, and that his termination for leaving his worksite without proper authorization and insubordination was pretextual. He also claimed other non-African-American trainees were not disciplined similarly. The court granted summary judgment in favor of MTA Metro-North, finding that Howard failed to provide sufficient evidence to create a genuine issue of material fact that the employer's stated non-discriminatory reasons for termination were a pretext for racial discrimination. Subsequently, Howard filed a motion for relief from judgment under Rule 60(b), citing alleged mistakes, fraud by the defendants, and newly discovered evidence concerning other trainees. The court denied this motion, concluding that Howard's arguments were either rearguments of prior points, lacked clear and convincing evidence of fraud, or the "new evidence" was either available during discovery or not sufficiently convincing to warrant relief.

Employment DiscriminationRacial DiscriminationTitle VIISection 1981Summary JudgmentPro Se LitigantMotion to Vacate JudgmentRule 60(b)Pretext for DiscriminationLocomotive Engineer Training Program
References
66
Case No. MISSING
Regular Panel Decision

American Train Dispatchers Ass'n v. Metro-North Commuter Railroad

Plaintiff American Train Dispatchers Association (ATDA) accused defendant Metro-North Commuter Railroad Company of violating the Railway Labor Act (RLA) by unilaterally implementing changes to work rules and conditions without prior union consultation. The changes concerned sick leave, vacation days, training time, work attire, and drug/alcohol testing. The court classified these disputes as either 'major' or 'minor' under the RLA. It found that the automatic requirement for doctor's certificates for sick days not contiguous to rest days, holidays, or vacation, and the new work attire policy constituted 'major disputes', and thus granted a permanent injunction to restore the status quo. However, the court deemed disputes over training time, single vacation days, and sick days contiguous to rest days/holidays/vacation as 'minor disputes', denying injunctive relief for these. The court also denied injunctive relief for random drug testing due to insufficient evidence, noting that the issue of drug testing as part of regular medical examinations was being addressed in a separate ruling.

Railway Labor ActMajor DisputeMinor DisputeInjunctive ReliefWork RulesSick Leave PolicyVacation PolicyTraining TimeDress CodeDrug Testing
References
14
Case No. MISSING
Regular Panel Decision
Jul 07, 1994

United Transportation Union Local Unions 385 & 77 v. Metro-North Commuter Railroad

This is a declaratory judgment action filed by the United Transportation Union and the International Brotherhood of Electrical Workers (collectively, 'the Union') against Metro-North Commuter Railroad Company ('Metro'). The Union challenges Metro's Rule P as a violation of 45 U.S.C. § 60 (Section 60) of the Federal Employer's Liability Act (FELA). Rule P restricts employees from divulging company information or giving statements about accidents to external parties without company authorization, which the Union argues prevents employees from voluntarily furnishing information to interested parties as protected by Section 60. Metro moved to dismiss the complaint for lack of subject matter jurisdiction, contending the dispute is governed by the Railway Labor Act (RLA) and its exclusive grievance resolution procedures. The court denied Metro's motion, concluding that the Union's claim involves the interpretation of a federal statute (Section 60) and is therefore within federal jurisdiction, not preempted by the RLA.

Federal Employer's Liability ActFELARailway Labor ActRLASubject Matter JurisdictionDeclaratory JudgmentRule 12(b)Labor DisputesCollective Bargaining AgreementPreemption
References
5
Case No. ADJ7582920
Regular
Mar 07, 2014

CRAIG SCHULTZ vs. JOINT TEST, TACTICS \u0026 TRAINING/JT3, THE HARTFORD

The Workers' Compensation Appeals Board (WCAB) reversed a prior finding, holding that the applicant's injury sustained during his commute to work is barred by the "going and coming" rule. While the WCJ found a transportation exception applied due to the employer potentially benefiting from the applicant's personal vehicle, the WCAB found no such exception was proven. The Board emphasized that the applicant was commuting outside of work hours in his personal car, and no evidence indicated he was engaged in a special mission or that the employer required him to use his own vehicle. Therefore, the applicant's claim was denied as it did not arise out of or occur in the course of employment.

Going and Coming RuleTransportation ExceptionIndustrial InjuryTechnical DrafterEdwards Air Force BasePersonal Vehicle UseEmployer BenefitCourse of EmploymentSpecial MissionLabor Code Section 3600
References
15
Case No. MISSING
Regular Panel Decision

State, Texas Department of Human Services v. Penn

This appeal concerns a judgment in a civil action for worker's compensation death benefits. The appellee, a minor child of decedent Barbara Jean Penn, was awarded benefits by a jury for injuries Penn sustained in a traffic accident while commuting to work, leading to her death. The appellant challenged the verdict, arguing there was no evidence that Penn's injury occurred in the course of her employment, specifically addressing exceptions to the rule that commuting is non-compensable. The court examined whether transportation was furnished or paid for by the employer, or if Penn was on a 'special mission.' Finding no evidence to support either exception, the appellate court concluded the injury was not compensable. Therefore, the judgment of the trial court was reversed, and judgment was rendered for the appellant.

Worker's CompensationDeath BenefitsCourse of EmploymentCommuting RuleSpecial Mission ExceptionSufficiency of EvidenceNo Evidence PointAppellate ReviewTexas LawEmployment Accident
References
11
Case No. 01-23-00245-CV
Regular Panel Decision
Apr 24, 2025

Johnnie Melton and Shelley Melton v. Big Creek Construction, Ltd. and WFMM, LLC

Appellants Johnnie and Shelley Melton sued Appellees Big Creek Construction, Ltd. and WFMM, LLC for negligence after Johnnie Melton was severely injured in a head-on vehicle collision with Tomas Treto-Trinidad, an employee of Big Creek. The Meltons brought claims for direct liability (negligence, negligent entrustment, negligent supervision or control, negligent training, and gross negligence) and vicarious liability. The central issue was whether Trinidad was acting in the course and scope of his employment at the time of the collision, invoking the 'coming and going rule' and its 'special mission exception.' Big Creek and WFMM moved for summary judgment, arguing Trinidad was commuting and had violated company policy by using a company trailer and fuel card for personal travel while intoxicated. The trial court granted summary judgment in favor of Big Creek and WFMM. The Court of Appeals affirmed the trial court's decision, concluding that Trinidad was commuting and not acting in the course and scope of his employment, and the 'special mission exception' did not apply as his actions were not an assigned duty for the employer's benefit.

Summary JudgmentVicarious LiabilityRespondeat SuperiorNegligenceCourse of EmploymentComing and Going RuleSpecial Mission ExceptionAutomobile AccidentDrunk DrivingEmployee Misconduct
References
55
Case No. MISSING
Regular Panel Decision

City of New York v. State

This case addresses the constitutionality of Chapter 5 of the Laws of 1999, which attempted to rescind New York City's commuter tax for New York State residents while retaining it for out-of-State commuters. The City of New York challenged the statute on home rule grounds, while residents of New Jersey and Connecticut, along with the State of Connecticut, argued it violated the Federal Constitution's Privileges and Immunities and Commerce Clauses. The Court held that Chapter 5 did not violate state home rule provisions. However, it found the statute unconstitutional under the Federal Privileges and Immunities and Commerce Clauses due to its discriminatory treatment of out-of-State commuters. Consequently, the 'poison pill' provision of Chapter 5 took effect, leading to the repeal of the entire New York City commuter tax as of July 1, 1999.

Commuter TaxHome Rule ProvisionsPrivileges and Immunities ClauseCommerce ClauseConstitutional ChallengeState TaxationTax DiscriminationNew York CityLegislative PowerStatutory Repeal
References
40
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