Clark v. Missouri, Kansas & Texas Railway Company

Undisputed Facts

This was a case in which the plaintiff employee sued the defendant’s employer for negligence, which resulted in the plaintiff’s injury. Even though most of the issues that arose from the different sides, the side of the plaintiff and that of the defendant, seem to disagree, there were some that were undisputed. Firstly, the defendant was within his mandate when he directed the plaintiff and other section employees in the section to gather the steers that were scattered after the wreck of the train.

As a freight company, such was bound to occur at any time and so, the section employees were supposed to be prepared to bring back the steers to the pens upon experiencing the wreck.

The plaintiff sustained the injuries in an area around Marthasville on May 10, 1897, when he was ordered to gather some of the steers that had run out of their pens as a result of a smash. One of the cars that had been broken contained Texas cattle. The Texas steers become so excited at the wreck-making and some of them to run from their pens.

The plaintiff and other section workers were directed by the defendant’s foreman to recollect the steers and take them back to their pens. They managed to drive the steers back to their pens, with exception of one that had gone towards the west and far from others. This is the steer that the plaintiff alleged to have caused him the injuries.

The defendant was not bound by any law to enquire about the nature of steers that he transported. He also did not have any obligation to inform the plaintiff about the viciousness of the steers as some of the steers were known to be dangerous and difficult to deal with. It was only ethical that the defendant informed the section employees about the nature of the steers on freight, but only if he knew (Nelson 65).

It was common knowledge that the Texas steers were violent and generally difficult to handle. They become more violent upon being excited by such things as a wreck. Given that the nature of the Texas cattle was known to every, there were high chances that the plaintiff as much as the defendant knew about this type of cattle. The plaintiff understood the Texas cattle and definitely the steer in question, and therefore, it was unnecessary for the defendant to inform him again.

The fact that one of the judges of the St. Louis Court of Appeals dissented to the affirmation of the case, it was within the provision of the law that the case qualified to be heard in the Supreme Court. It did not matter even if the affirmation was reached lawfully, but the fact that one of the judges of the court of appeals held that the affirmation would be a conflict with some of the decisions that had been determined on other occasions (Nelson 966).

Analysis of the Plaintiff’s version of the Facts and Law

The plaintiff’s complaint is based on the defendant’s negligence (Klass 26). The plaintiff holds that the defendant had failed to adequately inform him that the steer in question was violent and dangerous, therefore, one that was quite difficult to handle. According to the plaintiff, the steer needed extra care, which could only be put in place if the defendant had disclosed the information regarding it.

The injuries that the plaintiff sustained directly resulted from the defendant’s negligence and failure to inform him about the nature of the steer, which happened to a Texas steer (Klass 26). These issues have been supported by facts and evidence by the plaintiff’s part of the story. The defendant’s business can be considered as one that was quite risky since it involved the Texas cattle. The cattle were known to be fierce and dangerous and a class of cattle that required effective measures to deal with.

The Texas cattle were known to become wilder and extremely excited as a result of even a small excitement of injury. They were different from the ordinary cattle, which were friendly and easier to handle. According to the plaintiff, the defendant was well aware that the steer in question was from Texas but deliberately hid the information from the employees working at the section side where he, the plaintiff, worked.

Whereas the plaintiff did not have knowledge concerning the Texas cattle, the defendant was much aware of the nature of these cattle. The plaintiff could not have acquired this information from anywhere else since the nature of the Texas steers was not commonly known within the State of Missouri.

As a result, it was not proper enough to assume that the plaintiff had the knowledge that the Texas cattle could get excited and become fierce as well as dangerous as a result of the shatter, which occurred during the freight. The defendant was likely to know how vicious these cattle could get as a result of excitement such as the one that was caused by the wreck.

Since the defendant knew that the steer was likely to become very dangerous and uncontrollable upon breaking loose from the cars and did not communicate this information to the plaintiff, indicated that the defendant did not care for the plaintiff’s safety. The plaintiff held that the immediate cause of his injuries was as a result of the attack, which could have been avoided only if; the defendant had passed the information to him regarding the steer’s change of state when excited.

Given that the plaintiff did not have any information regarding the Texas steer when excited, the promoting cause of his injury was as a result of the defendant’s negligence, omission, and failure to issue such information to the plaintiff before directing him to gather the cattle back to the pen. At this point, such information was crucial and would have helped to prevent the injuries that the plaintiff incurred.

Even though the injuries were not directly inflicted onto the plaintiff by the steer, they were caused by the excitement of the steer, which appeared to have become quite vicious.

To avoid getting into direct contact with the steer that had become extremely wild, the plaintiff was right to do what he thought would save him even if he sustained an injury afterward. Therefore, the plaintiff was not liable for any charges of negligence and imposing himself to dangers by his own actions (Nelson 115). In any case, the plaintiff assumed that his master, the defendant, would not send him to perform a task that the master knew very well had an unusual risk.

Analysis of the Defendant’s Version of the Facts and Law

The defendant, on the other hand, held a different version in relation to the plaintiff’s story. According to the defendant, the plaintiff had failed to clearly state out the cause of his injuries. He had also failed to adequately link his injuries to the defendant’s negligence of not informing him that the steer in question was dangerous type and was likely to be more vicious as a result of the excitement it had derived from the wreck.

The defendant had acted within his mandate when he sent the plaintiff to recollect the cattle that had broken loose from their pen as a result of the accidental wreck (Klass 27). There was no any element of negligence and omission when the defendant directed the plaintiff to perform the task, which the plaintiff claim resulted to the injuries he sustained.

It was not proven by the plaintiff that the defendant had failed to inform him that the steer was vicious and quite difficult to deal with, when it was necessary that the defendant should have done so. The defendant held that the plaintiff had failed to demonstrate how his efforts to save himself were necessary.

The claim that the plaintiff did not have even the slightest clue that the Texas cattle was vicious and difficult to deal with, especially in case of an excitement, did not hold. The plaintiff mentioned that the Texas steers were known for their fierceness and that they would become dangerous as a result of a small injury or excitement. This, according to the plaintiff, was a general knowledge, which meant that everybody knew about it. Therefore, the plaintiff also knew that the steer, which apparently was from Texas, was dangerous to handle and it was not proper that he had to wait to be re-informed by the defendant.

On the other hand, if it was not a common knowledge that the Texas cattle was fierce in nature and difficult to control, then both the plaintiff and the defendant did not know much about the vicious steer that allegedly caused the plaintiff to incur the injuries. And if this was the case, then, the defendant did not have any obligation to inform the plaintiff about the nature of the steer in question.

The defendant did not know about the cruelty and the danger that the steer would impose on the section employees upon occurrence of a wreck. Even if the defendant knew about the Texas steers, he could not know the particular steer that was extremely vicious and needed care of more than a single section employee.

The defendant was not by any law, bound to enquire about the nature of the steers that he transported just because he was doing such kind of business (Klass 28). Therefore, the plaintiff had apparently failed to show that he did not assume the risks that could emanate while gathering the steers back to the courier. He had also failed to challenge the fact that the defendant had only discharged his duties to him as provided for by the law, when he assigned him the task of gathering the steers.

Resolutions of the Supreme Court

The court had resolved that since one of judges of the St. Louis Court of Appeals had dissented to the affirmation of the decision of the circuit court, it was necessary to rehear and determine the case in the Supreme Court of Missouri (Congress 967). The Court of Appeals had ruled the case in favor of the plaintiff employee. The plaintiff recovered twenty-five dollars as a compensation for the injuries he sustained as a result of the uncontrollable steer.

The Constitution provided for rehearing of a case in the Supreme Court on the even that at least one of the judges of the Court of Appeals dissented to the decision reached by his colleagues in the court (Congress 967). The judge asserted that the decision, in which the plaintiff recovered a compensation for the injuries he sustained in his line of duty, was in conflict with the other decision that had been heard and determined before this case.

Although the St. Louis Court of Appeals maintained that there were no conflicts as claimed by the dissenting judge, the Supreme Court was required by the Constitution to handle the case afresh and not to remand it. Even if the Court of Appeals proved that the said conflicts did not exist, the fact that one of its judges felt that such conflicts existed was sufficient enough to qualify the case to be determined in the Supreme Court. The Supreme Court could also not remand the case even if it proved that the conflicts were non-existence, since this would be contrary to the provision of the Constitution (Congress 968).

Findings and Holdings of the Supreme Court of Missouri

The steer in question, a Texas type, was very unfriendly and for that reason, quite difficult to handle. The fact that the steer was also a victim of the wreck certainly made it more vicious and more difficult to control and may be, drive back into the pens. The wreck might have caused an injury or excitement that in turn, made it risky to handle the said steer. The plaintiff, unlike other section workers, had no experience in dealing with the Texas steers.

Unlike the plaintiff who did not have any information regarding the Texas cattle, the defendant’s foreman and other top officials were well aware of the nature of the steer. They were as well aware that the steer was certainly more vicious as a result of the excitement it had got from the accidental wreckage. The foremen and other officers of the defendant did not inform the plaintiff about the nature of the Texas steers thereby, leaving the plaintiff to remain ignorant about the facts that he ought to have known for the sake of his safety.

The foreman had directed the plaintiff and other section workers to drive the vicious Texas steer to its pen. The other section employees were aware that the steer was difficult to deal with, while the plaintiff was ignorant of these facts. However, the defendant’s foreman was within his line of duty when he directed the plaintiff with other workers to gather the cattle including the steer in question.

The plaintiff, on the other hand, insisted that he did not know that the steer that he been directed to drive to the pen was a Texas steer. He maintained that the defendant and the foreman knew that Texas steer was wild and difficult to control, but did not inform him. However, the plaintiff could not prove that the defendant and the foreman knew about the steer. The plaintiff also mentioned that it was dark and so, he could not identify the steer as a Texas type. If it was dark as the plaintiff claimed, then the information regarding the steer would not have been of much importance.

The claims that the plaintiff did not know that the steer was wild and required a lot of caution, were not reflected in his actions. The plaintiff, unlike his colleagues Jim and George, was armed with a big long club, a clear indication that he knew that the steer was dangerous. The plaintiff had also mentioned that the steer acted wild on seeing them and then ran far from the point where it was standing at the moment they appeared.

When they decided to follow the steer again, it was Jim who was in front, then followed George. The plaintiff came last. The plaintiff claimed that he heard a warning from Jim, but did not hear any from George, who probably was closer to him. He also mentioned that he saw Jim jumping for his safety as the wild steer was coming towards them. The plaintiff therefore, had an ample time to find the most appropriate ways that would save him from the steer, but unfortunately, waited until the steer was just a few distance from him.

The place where the plaintiff sustained the injuries was so rugged that it was not easy to avoid incurring such injuries. The place was on an embankment that was approximately fifteen feet from the level ground. The embankment was also wider at the bottom as compared to the top. The bottom of the pit was full of mud. The plaintiff mentioned that it was difficult for him to control his body when he jumped down the embankment. The slope was so steeply that it resulted in a great momentum. If this was the case, then even knowing that the steer was a Texas type was not going to help the situation.

The plaintiff claimed that he was not informed by the defendant’s foreman about the nature of the steer, but his statements show that he had some information regarding the Texas cattle, from where the steer in question originated. For instance, the plaintiff admitted knowing that the Texas steers were vicious and for that reason, difficult to control. The plaintiff was certainly aware that the steer would become so wild when injured. He also mentioned that when they found, the steers in the field after the wreck, all of them appeared friendly and probably easy to handle. The only one that appeared unfriendly was the steer in question.

The Supreme Court held that the defendant was not liable for the injuries that the plaintiff sustained in his line of duty. The defendant’s foreman had acted within his mandate when he directed the plaintiff and other section employees to gather the steers, which included the steer in question. The plaintiff had simply performed his duty when he assisted in taking the steers into the pens. The fact that the defendant ran the business of transporting the steers, did not give him any obligation to enquire about the nature of the steers that he was transporting.

Comparison of the Supreme Court’s Decision to the Current Law

The holdings of the Supreme Court of the Missouri are in line with the current law. It is a fact that the defendant was not liable for the injuries that the plaintiff sustained in his line of duty (Nelson 256). The plaintiff was simply performing his duty when the accident occurred. The defendant’s foreman who directed the plaintiff to carry the task was equally within the line of his duty (Klass 30). Besides, it was a common knowledge that the Texas cattle was vicious in nature and therefore, difficult to deal with. The plaintiff had failed to take the most effective measure to prevent such injuries, given that he had enough time to do so.

The Supreme Court’s Decision and the Federal Employer Liability Act (FELA)

The Court’s decision could be seen to be harsher than the holdings of FELA. The FELA holds that a railroad employee is entitled to compensation upon sustaining injuries as a result of his master’s negligence or as a result of using faulty equipment. In the case of the steer, the defendant was to be held liable for the injuries sustained by the plaintiff, if the case was handled under FELA.

The fact that the defendant did not inform the plaintiff that the steer in question was very wild could be considered under FELA as negligence of the defendant. In addition, the wreckage would be considered to have resulted from the use of faulty and poorly maintained facilities. The plaintiff, under FELA, would have recovered more compensations than what the circuit court had decided (Congress 964).

Works Cited

Congress. United States Code. New York, NY: Government Printing office, 2009. Print.

Klass, Gregory. Contract Law in the USA. Austin, TX: Kluwer Law International, 2010. Print.

Nelson, Brian L. Law and Ethics in Global Business: How to Integrate Law and Ethics into Corporate Governance around the World. New York, NY: Routlage, 2006. Print.