Williamson v. Consolidated Rail Corp.

735 F. Supp. 648, 1990 U.S. Dist. LEXIS 5318, 1990 WL 57827
CourtDistrict Court, M.D. Pennsylvania
DecidedMay 2, 1990
DocketCiv. A. No. 88-1641
StatusPublished

This text of 735 F. Supp. 648 (Williamson v. Consolidated Rail Corp.) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williamson v. Consolidated Rail Corp., 735 F. Supp. 648, 1990 U.S. Dist. LEXIS 5318, 1990 WL 57827 (M.D. Pa. 1990).

Opinion

MEMORANDUM

CALDWELL, District Judge.

Defendant, Consolidated Rail Corporation (Conrail), has filed a motion for judgment notwithstanding the verdict and for a new trial. Plaintiff, Robert L. Williamson, brought this action under the Federal Employer’s Liability Act (FELA), see 45 U.S.C. § 51, to recover for injuries suffered while he was transferring cargo from a damaged trailer to another one at a train yard operated by his employer, Pennsylvania Truck Lines (PTL). The case was tried to a jury. They returned a verdict in plaintiff’s favor in the amount of $675,000 which was molded to $607,500 after taking into account their determination that plaintiff was ten per cent responsible for his injury.

Defendant contends that we have no jurisdiction over the action because plaintiff was not its employee. FELA provides a cause of action against a railroad for “any person suffering injury while he is employed by such carrier____” 45 U.S.C. § 51. Thus, if there is no employment relationship, there is no jurisdiction over the case. For FELA purposes “the question of employment, or master-servant status, [is] ... determined by common-law principles.” Kelley v. Southern Pacific Co., 419 U.S. 318, 323, 95 S.Ct. 472, 476, 42 L.Ed.2d 498, 505 (1974) (brackets added). Under the common law, one method of establishing an employment relationship is by showing that the servant or employee was “acting for two masters simultaneously.” Id. at 324, 95 S.Ct. at 476, 42 L.Ed.2d at 506. A servant is “a person employed to pe2rform services in the affairs of another and who with respect to the physical conduct in the performance of the services is subject to the other’s control or right to control.” Id., 95 S.Ct. at 476, 42 L.Ed.2d at 506 (quoting Restatement (Second) of Agency § 220(1)).

To show that plaintiff was not its employee Conrail discusses at great length the nature of his relationship with PTL. Conrail points out that Williamson was employed by PTL, received his paychecks from that company, and was subject to its supervision. Conrail treats these facts, admittedly of general relevance to the employment issue, as also relevant to the narrower issue of FELA employment. We disagree. The Court in Kelley focused upon control or the right to control at the time of the accident as the crucial inquiry. Thus, the Court stated that findings such as a lengthy tenure of employment with another company, work that was unskilled and payment on an hourly basis, while “generally relevant to the employment inquiry” were of no assistance in determining the railroad’s control or right of control over the plaintiff in that action. Id. at 327 n. 9, 95 S.Ct. at 478 n. 9, 42 L.Ed.2d at 508 [650]*650n. 9. The Fifth Circuit put the relevant inquiry as follows:

[Ujnder the FELA a worker can be the “employee” of a railroad even though carried on the employment rolls of another company and paid by that other company. The test of employment ... is whether the railroad has control of the employee or the right to control the employee. The law does not require that the railroad have full supervisory control. It requires only that the railroad, through its employees, plays “a significant supervisory role” as to the work of the injured employee.

Lindsey v. Louisville & Nashville Railroad Co., 775 F.2d 1322, 1324 (5th Cir.1985) (citing Kelley) (brackets added).

Nevertheless, while disagreeing with defendant over the applicable legal principles, we do agree with its position. While the issue is close, we conclude that we cannot assert jurisdiction over this FELA case. The record shows that at the time of the accident plaintiff was performing a not uncommon task in his capacity as an employee of PTL and was not at that time employed by Conrail.

PTL, a wholly owned subsidiary of Conrail, operates the Harrisburg Intermodal Terminal in the Lucknow area near Harrisburg, Pennsylvania, as an independent contractor for the defendant. Trailers, normally operated over the road as part of a tractor-trailer combination, arrive on Conrail railroad cars at the Terminal. Part of PTL’s job, and one of Williamson’s duties, was to unload the trailers from the railroad cars and notify the trucking companies responsible for transporting the goods from that point. On the date of the accident, October 23, 1986, plaintiff’s particular job assignment was to use a forklift to transfer goods from a damaged trailer to an undamaged one. Plaintiff was injured when the damaged trailer’s dolly legs collapsed and the front end of the trailer went to the ground. Plaintiff was seated on a forklift at the rear of the trailer, but was still shaken when the front of the trailer collapsed.

The strongest evidence in plaintiff’s favor arises from the presence of a Conrail damage inspector during the transfer of the goods. Conrail was responsible for the contents of the damaged trailer and was making a record of any damages. Accordingly, plaintiff testified that as he moved the pallets from the one trailer to the other, the inspector would examine them for possible damage. Plaintiff further testified that he would do whatever the inspector told him to do in regard to any particular load.1 (N.T. 16). This evidence was buttressed by David R. Estes, the inspector, who testified that if he saw plaintiff doing something that might damage the cargo during the transfer process, he would mention it to him so Williamson would correct it the next time. Estes also told plaintiff the pallets should be transferred to the new trailer in an alternating fashion, one pallet in one side and the next beside it rather than running them down one side of the new trailer and then the other. Additionally, Estes had the authority to stop plaintiff from transferring a pallet if he saw it was damaged so a record could be made and to order the way in which pallets were transferred so that certain ones were placed at the rear of the trailer. (N.T. 144-45). The PTL terminal manager, James Ryan, concurred generally with this last statement of authority. (N.T. 109).

It is true that the foregoing supports the conclusion that there was some right of direction on the part of the inspector. But it was of a limited nature and for the sole purpose of fulfilling the inspector’s job to assess damage to the cargo. None of it was of a general supervisory nature going to the manner in which plaintiff performed his job. This case involves mere accommodation or coordination by two companies with a close working relationship, see Kel[651]*651ley, supra, and we lack jurisdiction over it under FELA.

Even if we were to find jurisdiction, we would have to grant a new trial because we agree with defendant that the verdict was against the great weight of the evidence. See Roebuck v. Drexel University, 852 F.2d 715 (8d Cir.1988). Defendant argues that plaintiff could not have suffered a very great impact from the collapse of the trailer legs and that a pre-existing injury is the main cause of his disability and pain.

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735 F. Supp. 648, 1990 U.S. Dist. LEXIS 5318, 1990 WL 57827, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williamson-v-consolidated-rail-corp-pamd-1990.