Consolidated Rail Corporation v. Gottshall, 512 U.S. 532 (1994)

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certiorari to the united states court of appeals for the third circuit

No. 92-1956. Argued February 28, 1994—Decided June 24, 1994*

In separate suits against petitioner Conrail, their former employer, respondents Gottshall and Carlisle each asserted a claim for negligent infliction of emotional distress under the Federal Employers' Liability Act (FELA). In Gottshall, the District Court granted summary judgment to Conrail. In reversing and remanding for trial, the Court of Appeals observed that most States limit recovery for negligent infliction of emotional distress through the application of one or more common-law tests. The court declared, however, that there is a fundamental tension between such restrictive tests and FELA's liberal recovery policy, and stated that the tests must be discarded when they bar recovery on "meritorious" FELA claims. The court held that the facts alleged in support of a FELA claim must provide a threshold assurance that there is a likelihood of genuine and serious emotional injury, and concluded that Gottshall had satisfied this threshold "genuineness" test and adequately alleged the usual FELA elements, including conduct unreasonable in the face of a foreseeable risk of harm. In Carlisle, the same court sustained a jury verdict against Conrail, "uphold[ing] for the first time a claim under the FELA for negligent infliction of emotional distress arising from work-related stress." Although it restated its Gottshall holding, the court shifted its primary emphasis to the foreseeability of the alleged injury and held, inter alia, that Carlisle had produced sufficient evidence that his nervous breakdown had been foreseeable to Conrail.

Held: 1. The proper standard for evaluating FELA claims for negligent infliction of emotional distress must be derived from FELA principles and relevant common-law doctrine. Pp. 541-549. (a) This Court's FELA jurisprudence outlines the proper analysis for determining whether, and to what extent, a new category of claims should be cognizable under the statute. First, the language, purposes, and background of the statute, along with the construction given to the statute by this Court, must be examined. Second, because FELA

*Together with Consolidated Rail Corporation v. Carlisle, also on certiorari to the same court (see this Court's Rule 12.2).

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