Case brief summary
A federal law called FELA lets railroad workers sue their employer for money damages when the employer's carelessness causes injury or death on the job. This case asks if it covers purely emotional harm.
Facts
Two railroad workers sued Conrail. Gottshall watched a coworker die from heat exhaustion and developed depression and PTSD. Carlisle, a dispatcher, had a nervous breakdown after years of stressful, understaffed overwork.
Procedural history
A trial court dismissed Gottshall's case, but an appeals court revived it using a new test. In Carlisle's case, a jury awarded damages and the same court upheld it. Conrail appealed both to the Supreme Court.
Issue
Can railroad workers recover damages under FELA for emotional distress caused by their employer's carelessness, and if so, what legal test should courts use to decide which emotional distress claims are allowed?
Holding
Emotional distress claims can be brought under FELA, but only if the worker was physically touched or placed in immediate danger of physical harm. Gottshall's case was sent back for review, and Carlisle's win was reversed.
Reasoning
Since FELA doesn't address emotional injuries directly, courts must rely on long standing legal principles. The zone of danger test fits FELA's original focus on physical risks and avoids turning the law into open-ended insurance for job stress.
Opinions
Majority (Thomas): Emotional distress claims are allowed under FELA, but only under the zone of danger test, which limits recovery to workers who faced physical danger themselves.
Concurrences (Souter): Agreed with the majority, stressing that courts must build a federal common law of negligence under FELA guided by evolving common law principles.
Dissent (Ginsburg): Would have allowed recovery based on whether the injury was genuine and severe, following the appeals court's more flexible and worker friendly approach, joined by Blackmun and Stevens.