BNSF Railway Company v. James E. Phillips

Summary

The Supreme Court of Texas held that James Phillips’s claims against BNSF Railway under the Federal Employers’ Liability Act and Locomotive Inspection Act were barred by the three-year statute of limitations. The court concluded that the evidence conclusively established that Phillips knew or should have known his spinal injuries were work-related no later than his 2003 diagnosis, although he filed suit in 2007. The court reversed the court of appeals and rendered judgment that Phillips take nothing.

Holdings

1. A plaintiff may not maintain an independent cause of action under the Locomotive Inspection Act; the LIA claim must be brought as part of an FELA action and is subject to FELA’s three-year limitations period.
2. In an FELA action involving a latent injury, the plaintiff bears the burden of proving that the lawsuit was timely filed.
3. A latent-injury FELA claim accrues when the plaintiff knows or should know the critical facts concerning the injury and its work-related causation; Phillips’s claim accrued no later than his 2003 diagnosis.
4. No evidence supported the jury’s finding that Phillips timely filed suit, and the conclusive evidence established that the claims were time-barred.

Questions Presented

1. Whether evidence supported the jury’s finding that Phillips timely filed his FELA and LIA claims.
2. Whether Phillips’s claims accrued, under the FELA discovery rule, no later than his 2003 diagnosis.
3. Whether the LIA claim was subject to the FELA three-year limitations period.

Disposition

reversed