Affolder v. New York, C. & St. L.R. Co
In Affolder v. New York, C. & St. L.R. Co., 339 U.S. 96, 70 S.Ct. 509, 94 L.Ed. 683 (1950), a worker had been injured chasing after a runaway chain of cars, which had broken away after two cars had failed to couple on impact.
Focusing on the question of whether the plaintiff could meet his burden by showing a failure to couple or whether he must also establish that the coupler was defective, the Court held that the former was sufficient.
Thus, "the plaintiff did not have to show a 'bad' condition of the coupler" and "neither evidence of negligence nor of diligence and care was to be considered on the question of this liability." Id. at 99, 70 S.Ct. at 511.
The Court held that the plaintiff could meet his burden under Sec. 2 of the Federal Safety Appliance Act ("FSAA")by showing a failure to couple automatically upon impact.
The railroad's duty to have couplers which couple automatically upon impact "is an absolute one requiring performance 'on the occasion in question.' " Id.
The plaintiff is not, therefore, required "to show a 'bad condition' of the coupler." Affolder, 339 U.S. at 99, 70 S.Ct. at 510-11.