NEW YORK CENTRAL RAILROAD COMPANY v. WHITE 243 U.S. 188 (1917)

The New York Workmen's Compensation Act of 1914 made employers liable to compensate injured workers in certain cases without regard to fault. The statute thereby departed from time-honored common law rules of liability, particularly the fellow-servant doctrine and contributory negligence. The act established a graduated scale of compensation based on the loss of earning power, prior wages, and the character and duration of the disability suffered. Death benefits would be paid according to the survivors' needs.

Here, a night watchman was injured while guarding tools and materials used in the construction of a new station and tracks designed for interstate commerce. A9–0 Supreme Court held that the watchman was not in interstate commerce within the meaning of the first employers ' liability act. Justice mahlon pitney, for the Court, declared that his work "bore no direct relation to interstate transportation." Pitney rejected claims that the New York act violated the fourteenth amendment's prohibition against a taking of property without due process of law and deprived both parties of the freedom of contract."It needs no argument to show that such a rule [fellow-servant] is subject to modification or abrogation by a state upon proper occasion." Because "the public has a direct interest in this as affecting the common welfare," the Court sustained the act as a reasonable exercise of the state police power. Pitney also rejected the argument that the exclusion of certain workers from the statute's coverage was an arbitrary classification in violation of the equal protection clause of the Fourteenth Amendment. He concluded that the classification was reasonable in view of the "inherent risks" associated with the various occupations.

David Gordon
(1986)