Cavanaugh v. Western Maryland Railway Co.
United States Court of Appeals for the Fourth Circuit
729 F.2d 289 (4th Cir. 1984)
Relevant factsFree
After being injured in a train collision, engineer Cavanaugh (plaintiff) sued his railroad employers (defendants) under FELA seeking $1,500,000; the railroads counterclaimed for $1,700,000 in property damage they alleged Cavanaugh's negligence caused, despite admitting they rarely brought such claims against employees. Cavanaugh moved to dismiss the counterclaim as barred by FELA, and the district court agreed and dismissed it; the railroads appealed.
IssueFree
Whether FELA bars a railroad defendant from filing a compulsory counterclaim for property damage in an employee's FELA personal-injury action against that railroad.