Johnson v. Southern Pacific Co.
| Johnson v. Southern Pacific Co. | |
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| Argued October 31, 1904 Decided December 19, 1904 |
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| Full case name | Johnson v. Southern Pacific Co. |
| Citations | 196 U.S. 1 (more) |
| Prior history | 117 F. 462 (8th Cir. 1902) |
| Court membership | |
| Case opinions | |
| Majority | Fuller, joined by unanimous |
| Laws applied | |
| Railroad Safety Appliance Act | |
Johnson v. Southern Pacific Co., 196 U.S. 1 (1904) was a case before the United States Supreme Court. It interpreted the words "any car" in the Railroad Safety Appliance Act prohibiting common carriers from using any car in moving interstate commerce not equipped with automatic couplers. In doing so, it overturned the Eighth Circuit in Johnson v. Southern P. Co., 117 F. 462 (8th Cir. 1902)
August 5, 1900, Johnson was acting as head brakeman on a freight train of the Southern Pacific Company, which was making its regular trip between San Francisco, California, and Ogden, Utah. On reaching the town of Promontory, Utah, Johnson was directed to uncouple the engine from the train and couple it to a dining car, belonging to the company, which was standing on a side track, for the purpose of turning the car around preparatory to its being picked up and put on the next west-bound passenger train. The engine and the dining car were equipped, respectively, with the Janney coupler and the Miller hook, so called, which would not couple together automatically by impact, and it was, therefore, necessary for Johnson, and he was ordered, to go between the engine and the dining car, to accomplish the coupling. In so doing Johnson's hand was caught between the engine bumper and the dining car bumper and crushed, which necessitated amputation of the hand above the wrist.
The brakeman brought his action in a state district court (District Court of the First Judicial District of Utah). The case was subsequently removed to a federal trial court (Circuit Court of the United States for the District of Utah) on the ground of diversity of citizenship.
On trial, after plaintiff had rested its case, the Court granted defendant's motion to instruct the jury to find in its favor (directed verdict).
Plaintiff carried the case to the Circuit Court of Appeals for the Eighth Circuit and the judgment was affirmed. 117 Fed. Rep. 462.
The case was brought to the Supreme Court on certiorari, and also on writ of error.
Appellant claimed that he was relieved of an assumption of risk under common law rules. The case involved the application of a congressional act in respect of automatic couplers, the primary question being whether locomotives were required to be equipped with couplers. Another issue was that the dining car was empty and was not used in moving interstate traffic.
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