LeDure v. Union Pacific Railroad Company
The Facts
Justin LeDure, a Union Pacific employee, was injured during the course of his railroad employment and brought a FELA claim seeking compensation. The question before the Court was whether LeDure had presented sufficient evidence to survive summary judgment on the negligence element of his FELA claim. The Seventh Circuit had ruled against LeDure, and he sought Supreme Court review.
The Application
Under FELA's relaxed negligence standard, LeDure needed to show only that Union Pacific's negligence played any part in causing his injury a threshold lower than ordinary tort negligence. The evidence LeDure presented, however, failed to meet even this reduced burden, as the Seventh Circuit determined in granting summary judgment to the railroad. The Supreme Court's equally divided affirmance left this judgment intact within the Seventh Circuit, though it created no binding precedent on the sufficiency of evidence in FELA cases nationwide.
The Conclusion
**The per curiam affirmance by an equally divided Court leaves the Seventh Circuit's judgment in place but sets no national standard.** The result is a defendant victory for Union Pacific, but FELA claimants in other circuits retain the benefit of potentially more favorable standards in their jurisdictions.
No circuit court data for this case.
Case Analysis
Overview
The Supreme Court affirmed the Seventh Circuit in a Federal Employers' Liability Act case involving a Union Pacific railroad employee who claimed the company's negligence caused him injuries. The Court's decision, issued per curiam after an equally divided Court, left the Seventh Circuit's judgment in place without establishing binding national precedent.
Facts
Justin LeDure, a Union Pacific employee, was injured during the course of his railroad employment and brought a FELA claim seeking compensation. The question before the Court was whether LeDure had presented sufficient evidence to survive summary judgment on the negligence element of his FELA claim. The Seventh Circuit had ruled against LeDure, and he sought Supreme Court review.
Issue
Whether a railroad employee suing under the Federal Employers' Liability Act presented sufficient evidence of employer negligence to submit the case to a jury.
Rule
The Federal Employers' Liability Act imposes a lower negligence standard than common law tort, requiring only that the railroad's negligence played any part in producing the employee's injury. Hatch v. Mortonson (1956) and Rogers v. Missouri Pacific Railroad (1957) established the relaxed causation standard applicable to FELA claims.
Analysis
Under FELA's relaxed negligence standard, LeDure needed to show only that Union Pacific's negligence played any part in causing his injury. A threshold lower than ordinary tort negligence. The evidence LeDure presented, however, failed to meet even this reduced burden, as the Seventh Circuit determined in granting summary judgment to the railroad. The Supreme Court's equally divided affirmance left this judgment intact within the Seventh Circuit, though it created no binding precedent on the sufficiency of evidence in FELA cases nationwide.
Conclusion
**The per curiam affirmance by an equally divided Court leaves the Seventh Circuit's judgment in place but sets no national standard.** The result is a defendant victory for Union Pacific, but FELA claimants in other circuits retain the benefit of potentially more favorable standards in their jurisdictions.
Notes
OT2021. Added via SCOTUS bulk import 2026-05-14
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