Union Pacific Railroad Company v. Seymore Williams

Summary

The Supreme Court of Texas held that a jury should receive a foreseeability instruction when evidence is disputed regarding whether a railroad knew or should have known that workplace conditions could cause the employee's injury under the Federal Employers' Liability Act. The court overruled Union Pacific Railroad Co. v. Mitchell to the extent it rejected such an instruction in those circumstances, and held that Union Pacific preserved its jury-charge complaint by submitting a substantially correct written instruction. The court reversed the court of appeals' judgment and remanded for further proceedings.

Holdings

1. When evidence about foreseeability as it relates to a railroad's duty is disputed, the trial court must instruct the jury to determine whether the railroad knew or should have known that a dangerous condition could result in the employee's injury.
2. Union Pacific preserved error because its written proposed instruction was substantially correct under the federal law governing FELA burdens of proof, even though it used the phrase "you must be satisfied."
3. The refusal was reversible error because the disputed foreseeability evidence required a jury determination of duty, and the absence of the instruction probably caused the rendition of an improper judgment.

Questions Presented

1. Whether, in a FELA action, the trial court was required to submit a jury instruction concerning foreseeability as it relates to the railroad's duty when the evidence about the railroad's actual or constructive knowledge of a dangerous condition was disputed.
2. Whether Union Pacific preserved its jury-charge complaint by submitting a written instruction stating that the jury must be satisfied that Union Pacific had actual or constructive notice of the dangerous condition.
3. Whether the refusal to submit the foreseeability instruction was reversible error.

Disposition

reversed_and_remanded