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Case Law Database

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

Case No. 09-23-00203-CV
Regular Panel Decision
Jun 19, 2025

Jermaine Thomas v. Iron Horse Terminals, L.L.C.

Jermaine Thomas appealed a summary judgment granted in favor of Iron Horse Terminals, L.L.C. (IHT). Thomas, a train conductor, was injured while working for IHT and sought remedies under the Federal Employers’ Liability Act (FELA), alleging IHT was a common carrier. IHT denied FELA applicability, arguing it was a workers' compensation subscriber and not a common carrier. The appellate court affirmed the trial court's decision, finding that IHT did not meet the criteria of a common carrier under FELA, specifically lacking common ownership with a railroad, contractual relationship for common carrier functions, and remuneration from a common carrier. Consequently, Thomas's FELA claim was not applicable.

FELACommon CarrierSummary JudgmentWorkers' CompensationInterstate CommerceRail ServiceEmployer LiabilityTexas LawAppellate ReviewLone Star Factors
References
13
Case No. MISSING
Regular Panel Decision

Greene v. Long Island Railroad

Plaintiff Sean Greene, an MTA police officer, suffered an on-the-job injury while a passenger in a surveillance vehicle patrolling an LIRR station. He sued MTA and LIRR under the Federal Employers Liability Act (FELA), 45 U.S.C. § 51, alleging negligence. Defendants moved for summary judgment, arguing MTA is not a common carrier under FELA, and LIRR was neither Plaintiff's employer nor was Plaintiff a 'borrowed servant.' The court, though expressing reservations about the antiquated nature of FELA, held that the MTA operates a common carrier for employees like Plaintiff assigned to its interstate commuter rail operations. Consequently, the court denied the defendants' motion for summary judgment, allowing Plaintiff to proceed under FELA.

FELACommon CarrierRailroad LawSummary JudgmentEmployer LiabilityInterstate CommerceMetropolitan Transit AuthorityLong Island RailroadPublic Authorities LawNegligence
References
15
Case No. MISSING
Regular Panel Decision
Apr 13, 2009

Zuckerberg v. Port Authority

The injured plaintiff, a police lieutenant for the Port Authority, sustained injuries after tripping over a door saddle at John F. Kennedy International Airport. After receiving workers' compensation, he and his wife filed a lawsuit against the Port Authority under the Federal Employers' Liability Act (FELA). The Port Authority moved for summary judgment, arguing FELA was inapplicable and workers' compensation was the exclusive remedy. The Supreme Court granted the motion, concluding that FELA did not apply because the alleged negligence was not connected to the Port Authority's interstate railway operations. This appellate court affirmed the decision, emphasizing that for FELA to apply, the defendant's negligent act must be committed while it is engaging in interstate commerce related to its railway operations, which was not the case here as the accident occurred in an airport office.

Federal Employers' Liability ActPersonal InjurySummary JudgmentInterstate CommerceRailroad LiabilityPolice EmploymentAirport AccidentPort AuthorityExclusive RemedyAppellate Review
References
8
Case No. MISSING
Regular Panel Decision
Feb 21, 1989

Smoot v. New York Susquehanna & Western Railway Corp.

Plaintiff Gregory Smoot was injured in 1986 while operating railroad equipment. He filed an action under the Federal Employers' Liability Act (FELA) against New York Susquehanna and Western Railway Corporation and Delaware Otsego Corporation. Concurrently, he filed a workers' compensation claim against his direct employer, Timothy E. Wilsey, General Contractor, Inc. The defendants moved for summary judgment, arguing Smoot was an independent contractor, ineligible for FELA coverage, and estopped from pursuing the FELA action due to receiving workers' compensation benefits. The court, citing established Supreme Court precedent, found that genuine factual issues existed regarding Smoot's employment status with the railroad, which typically requires a jury's determination. The court also clarified that Smoot's acceptance of workers' compensation benefits from his direct employer did not waive his FELA claim against the railroad defendants. Therefore, the defendants' motion for summary judgment was denied and dismissed.

Federal Employers Liability ActFELASummary JudgmentDual EmploymentIndependent ContractorWorkers' CompensationEstoppelRailroad AccidentPersonal InjuryBorrowed Servant
References
20
Case No. 01-18-00181-CV
Regular Panel Decision
Jan 28, 2020

Richard Haynes v. Union Pacific Railroad Company, a Corporation

Richard Haynes, a carman for Union Pacific Railroad Company (UP), was injured while leaving work and subsequently sued UP under the Federal Employment Labor Act (FELA). A jury found both parties negligent, but the trial court reduced Haynes's damages based on his contributory negligence and liens. On appeal, Haynes contested jury instructions and judicial bias, while UP cross-appealed on FELA applicability and sought an offset for railroad retirement taxes. The appellate court affirmed FELA's applicability, found no trial errors or bias, but modified the judgment to grant UP the requested offset, thus affirming the judgment as modified.

Federal Employment Labor ActRailroad AccidentPersonal InjuryContributory NegligenceJury InstructionJudicial ConductPre-existing ConditionDamages ApportionmentAppellate ProcedureWage Loss Offset
References
39
Case No. MISSING
Regular Panel Decision
Aug 23, 2002

Linetskiy v. New York City Transit Authority

Alex Linetskiy, an employee of the New York City Transit Authority (TA), sustained an eye injury at work and, along with his wife, sued the TA for personal injuries, alleging a violation of the Federal Employers’ Liability Act (FELA) for not providing protective goggles. The TA moved to dismiss, asserting the Workers’ Compensation Law as an affirmative defense. The Supreme Court, Kings County, granted the TA's motion, ruling that FELA did not apply to the TA because it is not a common carrier engaged in interstate commerce. This decision was affirmed on appeal, distinguishing the TA from other railroads covered by FELA, such as the Long Island Rail Road, by noting the TA only carries passengers intrastate.

FELAWorkers' Compensation LawPersonal InjuryInterstate CommerceCommon CarrierNew York City Transit AuthorityPreemptionAffirmative DefenseAppellate ReviewJurisdiction
References
17
Case No. MISSING
Regular Panel Decision

Simmons v. Texas City Terminal Railway Co.

This case examines whether an injured maritime employee, covered by the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA), can opt to sue under the Federal Employers’ Liability Act (FELA). The appellant, Leon A. Simmons, a guard for Texas City Terminal Railway Company, suffered a broken leg on the docks and initially filed a FELA suit. The trial court granted summary judgment, determining LHWCA was the exclusive remedy. The appellate court affirmed this decision, holding that LHWCA's exclusivity provision (33 U.S.C. § 905(a)) precludes negligence actions against employers and that LHWCA and FELA are mutually exclusive statutes designed for distinct worker categories.

Longshoremen’s and Harbor Workers’ Compensation ActFederal Employers’ Liability Actexclusive remedymaritime employmentrailroad employmentnegligenceworkers' compensationstatutory interpretationpersonal injuryappellate review
References
18
Case No. MISSING
Regular Panel Decision

Philipson v. Long Island Rail Road

Plaintiff, an employee of the Long Island Rail Road (LIRR), brought an action under the Federal Employer’s Liability Act (FELA) alleging injuries from loud telephone sounds. LIRR, the defendant, impleaded the New York Telephone Company, claiming the latter's failure to maintain lines led to the issue. Plaintiff sought to amend her complaint to assert a direct common law negligence claim against New York Telephone Company and to adjust the reported accident date. The court granted the motion, determining it had the constitutional power to hear the non-federal claim due to a 'common nucleus of operative facts' with the federal FELA claim, and found no congressional intent in FELA to negate such pendent jurisdiction.

Federal Employers Liability ActFELAPendent JurisdictionCommon Law NegligenceThird-Party ClaimMotion to AmendSubject Matter JurisdictionCommon Nucleus of Operative FactsPersonal InjuryTelephone Lines
References
5
Case No. MISSING
Regular Panel Decision

Lewis v. National Railroad Passenger Corp.

Plaintiff Ian E. Lewis sued his employer, National Railroad Passenger Corp. (Amtrak), under the Federal Employers’ Liability Act (FELA) after being shot by his brother at work. The case centered on whether Amtrak acted reasonably to ensure Lewis’s safety after receiving warnings about the threat. Amtrak sought to limit its liability under CPLR article 16 by apportioning fault to the nonparty shooter, despite not pleading it as an affirmative defense. The court denied Amtrak's application, ruling that CPLR article 16 is a substantive State law that cannot diminish the Federal rights provided by FELA. The decision emphasized FELA's broad remedial purpose to ensure liberal recovery for injured railroad workers and shift the burden of loss to carriers.

Federal Employers’ Liability ActFELACPLR article 16Apportionment of liabilityNegligent tortfeasorIntentional tortfeasorPersonal injuryRailroad workerPreemptionSubstantive law
References
13
Case No. Docket No. 12
Regular Panel Decision

PITTER v. Metro-North Commuter Railroad

This decision and order addresses defendant Metro-North Commuter Railroad's motion in limine regarding the upcoming trial in a FELA negligence claim brought by plaintiff Perry Pitter for an eye injury. Metro-North sought to preclude various testimonies and documentary evidence, particularly concerning Pitter's employment termination, arguing irrelevance and wrongful termination claims. The court largely denied Metro-North's requests, affirming that testimony and evidence relating to Pitter's lost employment and wages could be relevant to consequential damages under FELA's relaxed causation standard. However, the court granted the exclusion of Pitter’s Notice to Admit. The decision underscores the broad scope of FELA damages for consequential injuries arising from employer negligence.

FELA ClaimMotion in LimineNegligenceEye InjuryLost WagesConsequential DamagesRailway Labor ActFRE 402CausationEconomic Harms
References
11
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