Atchison, Topeka & Santa Fe Ry. Co. v. Buell
In Atchison, Topeka & Santa Fe Ry. Co. v. Buell, 480 U.S. 557, 107 S.Ct. 1410, 94 L.Ed.2d 563 (1987), the Supreme Court addressed whether negligent infliction of an emotional injury is actionable under Federal Employers' Liability Act (FELA).
The employee there brought a FELA action alleging that the railroad harassed, threatened and intimidated him and that as a result he suffered "a mental breakdown, and certain associated physical disorders."
The Court first held that an employee retains his right to bring a FELA action for damages even though the injury was caused by conduct possibly subject to arbitration under the Railway Labor Act. 480 U.S. at 565-69, 107 S.Ct. at 1416-17.
The Court then turned to the railway's contention that an employee's "wholly mental injury" was not compensable under FELA.
It declined to resolve this issue, noting that the record was incomplete as to the exact nature of the allegedly tortious activity and the extent of the injuries allegedly suffered.
It opined that "broad pronouncements in this area may have to bow to the precise application of developing legal principles to the particular facts at hand." Id. 480 U.S. at 570, 107 S.Ct. at 1418.
In Atchison, Topeka & S.F. Ry. Co. v. Buell, 480 U.S. 557, 107 S.Ct. 1410, 94 L.Ed.2d 563 (1987), the Supreme Court held that the RLA does not preempt a claim under the Federal Employers' Liability Act (FELA).
The union member in Buell alleged that he suffered severe personal injuries as a result of a railroad's failure to provide him a safe place to work.
In rejecting the argument that his FELA claim was preempted by the RLA, the Supreme Court noted that the FELA provides railroad workers with substantive protection against negligent conduct.