HANMANN v. Metro-North Commuter Railroad
Plaintiff Craig Hanmann initiated an action against his employer, Metro-North Commuter Railroad, under the Federal Employers’ Liability Act (FELA), alleging negligence for injuries sustained at work and subsequent exacerbation due to delayed authorization for back surgery. Hanmann claimed Metro-North failed to provide a safe workplace and suitable tools, and that its Claims Department improperly interfered with the medical authorization process, prolonging his pain and suffering. Metro-North sought partial summary judgment, contending that the 'interference' claim constituted a 'minor' labor dispute governed by the Railway Labor Act (RLA), thus placing it outside the court’s jurisdiction. The court rejected this argument, ruling that the plaintiff’s claim was rooted in negligence, not a collective bargaining agreement interpretation, and was therefore within the scope of FELA. Consequently, the defendant’s motion for partial summary judgment was denied.