Terry Boyd v. BNSF Railway Company

Summary

The Minnesota Supreme Court held that the Federal Employers’ Liability Act (FELA) requires application of the substantive-procedural preemption test in state court proceedings. The court concluded that Minnesota Rule of Civil Procedure 68.03(b)(2), which permits plaintiffs to recover double costs after rejecting a settlement offer, is substantive and is not authorized by federal law. The court reversed the award of double costs and remanded for entry of an amended judgment.

Holdings

1. The Monessen substantive-procedural two-step analysis, rather than the Felder field-preemption analysis, governs whether a state law may be applied in a state-court FELA action.
2. FELA preempts Minn. R. Civ. P. 68.03(b)(2) because the rule’s double-costs remedy is substantive and federal law does not authorize plaintiffs to recover double costs in FELA actions.

Questions Presented

1. What preemption framework governs whether a state rule may be applied in a state-court FELA action?
2. Does FELA preempt Minn. R. Civ. P. 68.03(b)(2), which permits a plaintiff to recover double costs after a defendant rejects a settlement offer?

Disposition

reversed_and_remanded