Thomas v. Grigorescu
Plaintiffs, employees of National Railroad Passenger Corporation (Amtrak), were injured in an automobile accident while traveling in a taxi from their rail-yards to a hotel during a required layover in New York. They sought damages from Amtrak under the Federal Employers’ Liability Act (FELA), arguing that Amtrak owed them a non-delegable duty to provide safe transportation. Amtrak moved for summary judgment, contending it had no duty of care and was not liable for the taxi’s negligence, as it neither selected the taxi nor had a contract with the taxi company. The court granted summary judgment in favor of Amtrak, ruling that while the taxi ride could arguably be within the course of employment, FELA requires employer negligence or negligence by its agents. Crucially, the court found no contractual relationship between Amtrak and KIG Taxi, thus precluding agency and liability for the taxi's actions, and rejected the creation of a non-delegable duty in this context.