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New York Central Railroad Co. v. White | 243 U.S. 188 (1916)
If you slip and fall at a restaurant where you’re having dinner, you may be able to sue the restaurant for negligence. But if you slip and fall while you’re working at a restaurant, you may have to pursue recovery from your employer through workmen’s compensation. In New York Central Railroad Company versus White, we explore the constitutionality of state workmen’s-compensation laws.
The New York legislature enacted a workmen’s-compensation statute. Under that statute, certain employers in hazardous industries were required to compensate employees who were injured or killed on the job according to set rates. Employers were required to compensate employees regardless of fault as long as the employees didn’t willfully inflict their injuries and their injuries weren’t solely the result of their on-the-job intoxication. The statute replaced the common-law regime that had previously governed on-the-job injuries in New York. Under the common law, employers weren’t liable to injured employees unless the employer was negligent.
Jacob White was accidentally killed while performing his duties for a predecessor of the New York Central Railroad Company. White’s wife commenced a proceeding with the New York Workmen’s Compensation Commission. The commission awarded compensation. The New York Appellate Division and the New York Court of Appeals both affirmed. The United States Supreme Court reviewed the case on a writ of error.
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