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Winder v. Union Pacific RR. Co.

Citation: 296 Neb. 557Docket: S-15-1100

Court: Nebraska Supreme Court; May 5, 2017; Nebraska; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In the case of Winder v. Union Pacific Railroad Company, the plaintiff, a conductor, sustained a back injury while attempting to release a railcar handbrake. He filed a suit under the Federal Employers’ Liability Act (FELA) and the Federal Safety Appliance Acts (FSAA), alleging that the handbrake was inefficient, in violation of FSAA requirements. The trial court denied his motion for a directed verdict, and the jury ruled in favor of Union Pacific. On appeal, the Nebraska Supreme Court affirmed the decision, highlighting that state courts apply local procedural rules to FELA claims unless federal law dictates otherwise, while substantive issues are governed by federal interpretations. The court also emphasized that a directed verdict is only appropriate when the evidence leaves no room for differing conclusions. In this case, the conflicting evidence regarding the handbrake's functionality warranted a jury determination. The court found that Winder failed to prove a specific defect or that the handbrake's failure constituted inefficiency, leading to the affirmation of the jury's decision in favor of Union Pacific.

Legal Issues Addressed

Application of Local Procedural Rules to FELA Claims

Application: State courts can apply their procedural rules to FELA claims unless federal law specifies otherwise, while substantive issues are governed by federal law.

Reasoning: State courts can apply local procedural rules to claims under FELA unless specified otherwise by federal law, while substantive issues are governed by the provisions of the act and relevant federal interpretations.

Definition of Efficient Handbrakes under FSAA

Application: Railroads must ensure railcars are equipped with efficient handbrakes, which are defined as adequate in performance.

Reasoning: Under FSAA, railroads must ensure that railcars are equipped with efficient handbrakes, defined as adequate in performance.

Evidence of Inefficient Handbrakes

Application: Employees can demonstrate inefficiency by proving a specific defect or showing the handbrake's failure to function correctly under normal operation.

Reasoning: Employees can demonstrate inefficiency of handbrakes either by proving a specific defect or by showing the handbrake's failure to function correctly under normal operation.

Jury Determination of Handbrake Functionality

Application: When evidence is conflicting regarding a handbrake's functionality, it is the jury's role to determine inefficiency.

Reasoning: In cases of conflicting evidence regarding the functionality of handbrakes, the determination of inefficiency is for the jury to decide.

Standard for Directed Verdicts

Application: A directed verdict is only appropriate when the evidence leads to a single, indisputable conclusion by reasonable minds, requiring a legal determination.

Reasoning: A directed verdict is appropriate only when the evidence leads to a single, indisputable conclusion by reasonable minds, thus warranting a legal determination.