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.