Norfolk & Western R. Co. v. Hiles, 516 U.S. 400, 5 (1996)
404
NORFOLK & WESTERN R. CO. v. HILES
Opinion of the Court
In 1873, Eli H. Janney patented a knuckle-style coupler that was to become the standard for the freight car couplers used even today.3 See Figure 1. The coupler had a bifurcated drawhead and a revolving hook, which, when brought in contact with another coupler, would automatically inter-lock with its mate.
Figure 1
The Janney coupler had several advantages over link-andpin couplers. Not only did it alleviate the problem of loose parts that plagued the link-and-pin coupler,4 it also allowed railworkers to couple and uncouple cars without having to
3 Janney was a dry goods clerk and former Confederate Army officer from Alexandria, Virginia, who used his lunch hours to whittle from wood an alternative to the link-and-pin coupler. See F. Wilner, Safety: "A great investment," Railway Age, Mar. 1993, p. 53 (hereinafter Wilner).
4 Automatic couplers also made possible the use of power air brakes, which had not been successfully used with link-and-pin couplers because of excessive slack in the coupling. See Hearings on S. 811 et al. before the Senate Committee on Interstate Commerce, 52d Cong., 1st Sess. (1892), reprinted in S. Rep. No. 1049, 52d Cong., 1st Sess., 9 (1892) (hereinafter Sen. Hearings).
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