Flemm v. Toledo & Ohio Central Railway Co.

10 Ohio N.P. (n.s.) 273

This text of 10 Ohio N.P. (n.s.) 273 (Flemm v. Toledo & Ohio Central Railway Co.) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Flemm v. Toledo & Ohio Central Railway Co., 10 Ohio N.P. (n.s.) 273 (Ohio Super. Ct. 1910).

Opinion

Evans, J.

The principal question presented and argued on the demurrer to the petition involves the constitutionality of the legislative act of February 28, 1909 (99 O. L., 25), known as the railroad employers’ liability, act. This act provides that:

Every railroad company operating any railroad which is in whole or in part within this state shall be liable for all damáges sustained by any of its employes by reason of personal injury or death of such employe:

1. .When such is caused by a defect in any locomotive, engine, car, etc., required by such company to be used by its employes in and about the business of their employment, if such defect could have been discovered by reasonable and proper care, and such injured employe shall not be deémed to have assumed the risk occasioned by such defect, and the continuance in employment after knowledge of such defect by any employe sha.]] not be deemed an act of contributory negligence.

[274]*274Such liability attaches under this paragraph 2, although the injury was caused by the carelessness or negligence of any other employe, officer or agent of such company. Section 2 of said act provides that in all actions hereafter brought against any railroad company operating any railroad in whole or in part within this state, for personal injury or death of an employe, the fact that the employe may have been guilty of contributory negligence shall not bar a recovery where his contributory negligence was slight and that of the employer was greater in comparison. But the damages shall be diminished by the jury in proportion to the amount of negligence attributable to such employe. All questions of negligence and contributory negligence shall be for the jury.

It is claimed on behalf of the demurrer that by the use of the words “or in part” embodied in said act,- that the entire act is unconstitutional in that it invades the power conferred, upon Congress by Article I, Section 8 of the federal Constitution. That section of the Constitution provides that: “Congress shall have power to regulate commerce with foreign nations, among the several states, and with the Indian tribes.”

It is urged that said act in question undertakes to regulate interstate commerce because by its provisions it applies to all railroads operated in whole or in part within this state. Many authorities are cited in support of this contention, among which are the employers ’ liability cases, 207 U. S., 463, and the case of State of Wisconsin v. C., M. & St. P. Ry. Co., reported in 19 L. R. A. (N. S.), 326. I have examined all the cases cited by counsel in their briefs, both on behalf of and against said demurrer, and have reached the conclusion that inasmuch as Congress, by the .act of April 22, 1908, the present employers’ liability act, has taken jurisdiction to regulate fully as to all railroads engaged in interstate commerce, whose roads are partly in one state and partly in another, that the Legislature in the act in question, in attempting to include in its operations railroads operating partly in this state, has invaded said section of the federal Constitution, and for this reason said act is inoperative as to all railroads which are partly in this state, for the [275]*275reason that such roads are necessarily engaged in interstate commerce. ' '■ ’

The employers’ liability cases (supra) I think are decisive on this question."

The most serious question, and the one that, in my opinion, is more difficult of solution, is whether the provisions of said act are separable, and if the part thereof that applies to railroads operated wholly within this state can stand, although the part thereof that applies to railroads partly in this state must fall.

It: is claimed on the part of defendant-that said employers’ liability cases and said Wisconsin case is authority for the contedtion that the provisions of the act in question are indivisible, and can not be separated so as to sustain it as to railroads wholly within the state.

The court in holding said employers’ liability act of 1906 unconstitutional did so on the ground that said act, which was one addressed to all common carriers employed in interstate commerce, imposed a liability upon such carriers in favor of any of their employes, without qualification or restriction as'to the nature of the business at the time of the injury, and that this, of necessity, includes subjects wholly outside of the power of Congress under the commerce clause of the Constitution.

It is argued here that said case is authority in point that the provisions of the legislative act here under consideration are so dependent upon each other that they are indivisible, and that effect can not be given to the provisions applicable to railroads-wholly within the state by separating them from the provisions as to railroads partly within the state, and, hence, that the entire act is invalid. The court in the employer’s liability cases did hold said provisions indivisible, and that they could not be separated so as to uphold said act as related and confined to employes engaged in interstate business, as distinguished from' employes engaged by such carriers solely in intrastate business.

The ground upon which -the court so interpreted said act was, that the court could not construe the words “any employe,” as found in the statute, to mean any employe when such employe is engaged only in interstate commerce, because this would require the court to write into the statute words of limitation and re[276]*276striction not found in it; In other words, as-1 understand the decision, in order to uphold the contention of the Attorney-General, the court would be required to employ the legislative prerogative of writing into the statute limitations and restrictions as to the character of the' business' in which the employes were engaged. The court also held that to so modify the statute the effect would bé to restrict the operation of the statute to the District of Columbia and the territories.

The' court held that, where a statute contains provisions which are constitutional and others which are not, effect may be given to the legal provisions by separating them from the illegal; that this applies .only to a case where the provisions are separable and" not dependent upon the other, and it is plain that'Congress would have enacted the legislation with the unconstitutional provisions eliminated. " ' ■

In the case of Wisconsin v. C., M. & St. P. Ry. Co., 19 L. R. A., 326, similar questions were presented. The question was also made in the "Wisconsin case, that if it be beyond the power of the' state to restrict the services of an operator engaged in moving interstate trains, it is competent to so restrict as to one engaged ' exclusively upon, trains or business 'wholly within' the state, and that' the law may be construed as so limited, and its validity as so limited be sustained. • ■

It will be .observed that in both the Wisconsin ease and said employers’ cases this principle wás sought'to be invoked as to railroads doing interstate business, but limited to its trains' and operators engaged exclusively in intrastate business for such railroads.

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Related

The Employers'liability Cases
207 U.S. 463 (Supreme Court, 1908)

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Bluebook (online)
10 Ohio N.P. (n.s.) 273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/flemm-v-toledo-ohio-central-railway-co-ohctcomplfrankl-1910.