LeDure v. Union Pacific Railroad Company

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Supreme Court of the United States
LeDure v. Union Pacific Railroad Company
Term: 2021
Important Dates
Argued: March 28, 2022
Decided: April 28, 2022
Outcome
affirmed
Vote
4-4
Majority
Per curiam

LeDure v. Union Pacific Railroad Company is a case that was decided by the Supreme Court of the United States on April 28, 2022, during the court's October 2021-2022 term. The case was argued before the court on March 28, 2022.[1]

The court affirmed the decision of the United States Court of Appeals for the 7th Circuit in a per curiam opinion.[2] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Bradley LeDure was a conductor for the Union Pacific Railroad Company. While preparing a locomotive to travel, he slipped on oil on the locomotive's walkway and fell. LeDure brought suit in federal court against Union Pacific for negligence, including a claim under the federal Locomotive Inspection Act (LIA). To hold an entity liable under the LIA, the locomotive must have been in use at the time of the incident at issue. The district court held that because the locomotive was stationary, was on a side track, and was part of a train still needing to be assembled, it was not in use at the time of LaDure's fall. The court therefore dismissed the suit against Union Pacific and, on appeal, the U.S. Court of Appeals for the 7th Circuit affirmed.[3] LeDure appealed to the U.S. Supreme Court. Click here to learn more about the case's background.
  • The issue: The case concerned the meaning of a locomotive being in use for purposes of liability under the Locomotive Inspection Act (LIA).
  • The question presented: "Whether a locomotive is in use on a railroad’s line and subject to the LIA and its safety regulations when its train makes a temporary stop in a railyard as part of its unitary journey in interstate commerce, or whether such use does not resume until the locomotive has left the yard as part of a fully assembled train, as held by the Seventh Circuit below, contrary to the decisions of this Court and other circuits."[4][5]
  • The outcome: The court affirmed the decision of the United States Court of Appeals for the 7th Circuit in a per curiam opinion.[2]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 7th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • April 28, 2022: The U.S. Supreme Court affirmed the U.S. Court of Appeals for the 7th Circuit's ruling.
    • March 28, 2022: The U.S. Supreme Court heard oral argument.
    • December 15, 2021: The U.S. Supreme Court agreed to hear the case.
    • December 10, 2020: The petitioner Bradley LeDure appealed to the U.S. Supreme Court.
    • September 18, 2020: The U.S. Court of Appeals for the 7th Circuit affirmed the decision of the U.S. District Court for the Southern District of Illinois that found a locomotive was not in use because it was on a side track being serviced.

    Background

    Bradley LeDure, the petitioner, was a conductor for the Union Pacific Railroad Company. As he was preparing a group of locomotives for departure, he slipped and fell while walking along locomotive UP5683's walkway. LeDure identified a substance on the walkway, reported the incident to his supervisor, and gave a written statement. Upon inspection by Union Pacific, the substance on the walkway was reported to be a "small amount of oil."[3]

    LeDure sued Union Pacific for negligence with one claim alleging a violation of the Locomotive Inspection Act (LIA). To hold a party liable under the LIA, courts have established the locomotive must have been in use at the time of the incident. The U.S. District Court for the Southern District of Illinois noted that circuits have different tests for determining when a locomotive is in use, but that the 7th Circuit precedent was set out in Lyle v. Atchison, T. S.F. Ry. Co. (1949), which held "to service an engine while it is out of use, to put it in readiness for use, is the antithesis of using it."[6] Using this standard, the district court found that because the locomotive was stationary, was on a side track, and was part of a train still needing to be assembled before it could be used in international commerce, it was not in use at the time of LeDure's fall.[3] Accordingly, the district court granted Union Pacific's motion to dismiss the lawsuit. On appeal, the U.S. Court of Appeals for the 7th Circuit affirmed.[3]

    On December 10, 2020, LeDure filed an appeal to the U.S. Supreme Court, and the court accepted the case on December 15, 2021.[7]

    Question presented

    The petitioner presented the following question to the court:[8][5]

    Question presented:
    “ Whether a locomotive is in use on a railroad’s line and subject to the LIA and its safety regulations when its train makes a temporary stop in a railyard as part of its unitary journey in interstate commerce, or whether such use does not resume until the locomotive has left the yard as part of a fully assembled train, as held by the Seventh Circuit below, contrary to the decisions of this Court and other circuits..[9] ”

    Oral argument

    Audio

    Audio of oral argument:[10]



    Transcript

    Transcript of oral argument:[11]

    Outcome

    The court affirmed the decision of the United States Court of Appeals for the 7th Circuit in a 4-4 per curiam opinion.[2] A per curiam decision is issued collectively by the court. The authorship is not indicated. Click here for more information.


    1. ↑ Note: Because Justice Amy Coney Barrett participated in the case as a judge on the 7th Circuit, she took no part in the consideration of the petition for writ of certiorari.
    2. ↑ 2.0 2.1 2.2 Supreme Court of the United States, LeDure v. Union Pacific Railroad Company - "Opinion," decided April 28, 2022
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Court of Appeals for the 7th Circuit, LeDure v. Union Pacific Railroad Company, decided June 17, 2020
    4. ↑ Note: A second question was presented in the petition for writ of certiorari, but the court limited its review to the first question only.
    5. ↑ 5.0 5.1 U.S. Supreme Court, "Viking River Cruises, Inc. v. Moriana: PETITION FOR A WRIT OF CERTIORARI," filed May 10, 2021
    6. ↑ U.S. Court of Appeals for the 7th Circuit, Lyle v. Atchison, T. S.F. Ry. Co., decided November 3, 1949
    7. ↑ U.S. Supreme Court, "Docket for 20-807," accessed December 17, 2021
    8. ↑ Note: A second question was presented in the petition for writ of certiorari, but the court limited its review to the first question only.
    9. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 28, 2022
    11. ↑ [URL Supreme Court of the United States, "Oral Argument - Transcript," argued DATE]
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