Case Citator › Seaboard Air Line Railway v. Horton

Seaboard Air Line Railway v. Horton

Is it still good law? What later courts have actually done to this case.

Superseded by statute
Court
Supreme Court of the United States
Citation
233 U.S. 492
Decided
Confirmed treatments
1
Flagged citations read
37 of 37
Citing cases (total)
37
Treatment dates
1944
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Seaboard Air Line Railway v. Horton's rule allowing assumption of risk as a defense under the Federal Employers’ Liability Act was superseded by Congress's 1939 amendment. All 37 flagged citations have been read, and the confirmed treatment is listed below.
More on how this was screened

Its separate holding that recovery requires railroad negligence continued to be applied after the amendment.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

37 later cases cite Seaboard Air Line Railway v. Horton; 37 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Superseded by Statute

  • The Eighth Circuit held that the 1939 amendment abolished the assumption-of-risk defense Horton had recognized and affirmed the refusal to instruct the jury on that defense.

    Chicago Great Western Ry. Co. v. Peeler · Eighth Circuit · filed

    Prior to the adoption of this amendment the courts generally accepted and applied the doctrine of assumption of risk to cases arising under the Act, except “in any case where the violation by such common carrier of any [Federal] statute enacted for the safety of employees’ contributed to the injury or death of such employee”, such as the Safety Appliance Acts. Seaboard Air Line v. Horton, 233 U.S. 492, 502, 503, 34 S.Ct. 635, 639, 58 L.Ed. 1062, L.R.A.1915C, 1, Ann.Cas.1915B, 475. In Tiller v. Atlantic Coast Line R. Co., 318 U.S. 54, 64, 63 S.Ct. 444, 450, 143 A.L.R. 967, the Supreme Court said: “The result [of the 1939 amendment] is an Act which requires cases tried under the Federal Act to be handled as though no doctrine of assumption of risk had ever existed.” ... Until the Supreme Court overrules the Tiller case, the construction placed upon the 1939 amendment in that case is binding upon this court as well as upon the district court. Under these circumstances it can not be said that the trial court erred in refusing the requested instruction on assumption of risk.
    Read the full opinion on CourtListener →

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