LeDure v. Union Pacific Railroad Co.

In LeDure v. Union Pacific Railroad Co., railroad employee Bradley LeDure slipped and fell on a locomotive that was stationary on a siding in Salem, Illinois. He sued his employer, Union Pacific, under the Federal Employers' Liability Act (FELA), alleging that the locomotive lacked required handrails or sill steps in violation of the Safety Appliance Act (SAA). The district court granted summary judgment for the railroad, and the U.S. Court of Appeals for the Seventh Circuit affirmed, holding that a stationary locomotive not attached to any cars was not a "vehicle" under the SAA, thus no strict liability applied. The U.S. Supreme Court unanimously reversed on April 28, 2022, in an opinion by Justice Neil Gorsuch. The Court ruled that the SAA's definition of "vehicle" includes any locomotive used on a railroad line, regardless of whether it is coupled to other equipment or in motion. The case was remanded for further proceedings.

The U.S. Supreme Court unanimously reversed the Seventh Circuit, holding that a locomotive is a "vehicle" under the Safety Appliance Act even when not attached to other rolling stock, and remanded the case for further proceedings consistent with this interpretation.

Whether a stationary locomotive that is not coupled to any railcars constitutes a "vehicle" under the Safety Appliance Act, thereby triggering strict liability under the Federal Employers' Liability Act.

The ruling significantly bolsters protections for railroad workers by making clear that safety appliance standards apply to locomotives independently of their connected status. It expands potential strict liability for railroads and reinforces a worker-friendly interpretation of FELA, influencing future injury litigation and railway safety compliance.