Kuhnel v. BNSF Ry. Co.

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Edwin Kuhnel, an employee of BNSF Railway Company, was injured during while working for BNSF. Kuhnel brought this action against BNSF under the Federal Employers’ Liability Act (FELA), alleging that his injuries were caused by BNSF’s failure to provide him with a reasonably safe place to work and its failure to take other appropriate safety measures. Pursuant to the jury’s general verdict, the district court entered judgment for BNSF. The court of appeals reversed, concluding (1) the district court’s jury instructions erroneously permitted the jury to decide, as a factual determination, whether BNSF was under a duty to provide a reasonably safe place to work; and (2) the general verdict rule did not bar the court from overturning the jury’s verdict. The Supreme Court reversed, holding that the jury instructions in this case did not rise to the level of plain error because the instructions implicitly recognized BNSF’s duty by requiring the jury to find that BNSF was negligent if it found that BNSF had failed to provide Kuhnel with a reasonably safe place to work. View "Kuhnel v. BNSF Ry. Co." on Justia Law