Jennings v. Illinois Central Railroad
Theo Jennings, a trackman, sustained a disabling knee injury when a 'dry rotted' maul handle broke during spike driving. He sued Illinois Central Railroad Company under the Federal Employer’s Liability Act (FELA), alleging negligence due to an unsafe workplace and equipment. The trial court granted summary judgment for the Railroad. On appeal, the court affirmed, ruling that Jennings presented insufficient evidence of the Railroad's negligence. The court dismissed arguments regarding maul exposure and prior breakages as speculative and determined that using a maul was not inherently unsafe, thus not requiring the Railroad to provide automated alternatives.