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Consolidated Rail Corp. v. Gottshall | 512 U.S. 532 (1994)

Railroad workers in turn-of-the-century America often suffered serious injuries and even death on the job. In response to these dangerous working conditions, Congress passed the Federal Employers’ Liability Act, known as FELA, to hold the railroads responsible for harms negligently inflicted on their employees. In Consolidated Rail versus Gottshall, the United States Supreme Court contemplated FELA’s scope.

James Gottshall and Alan Carlisle worked for Consolidated Rail, known as Conrail. Gottshall suffered depression and post-traumatic stress disorder after witnessing a close friend die on the job. Carlisle experienced a nervous breakdown allegedly brought on by an exceptionally stressful work environment.

Both men sued Conrail for negligent infliction of emotional distress. In Gottshall’s case, the district court granted Conrail’s motion for summary judgment, ruling that FELA didn’t permit recovery for emotional injuries. Gottshall appealed, and the Third Circuit reversed. In Carlisle’s case, the jury returned a verdict for Carlisle. Conrail appealed, and the Third Circuit affirmed. The United States Supreme Court granted cert and consolidated the two cases.

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