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FELA Preempts State Law: FELA Worker Not Eligible for New York’s No Fault Insurance Benefits




by:
Christopher J. Hoare
Capehart & Scatchard, P.A. - New York Office

 
February 28, 2014

Previously published on February 21, 2014

In a recent New York State Court decision, Christin v. Metro North Commuter Railroad, et al., the court reaffirmed the FELA’s superiority over N.Y. State Insurance Law when it dismissed the lawsuit filed by a railroad worker who was injured while driving a railroad-owned truck in the course and scope of his duties.

In 2008, plaintiff was driving a company van while on duty as a car mechanic for Metro North.  Another vehicle ran a red light and struck the van causing injuries to Christin.   The company van he was driving at the time carried No-Fault Insurance coverage issued by Travelers Insurance as required by New York law.  The injured worker sued his railroad employer under the FELA for his pain and suffering, as well as past and future loss of earnings.  Plaintiff’s medicals were paid for by his railroad employer.

Shortly after filing his FELA suit, plaintiff also submitted a claim for no-fault benefits to Travelers.  Plaintiff claimed that despite his FELA suit for the same injuries and damages, he was also entitled to state no-fault benefits in the maximum amount of $2,000.00 per month  in disability payments.  The Travelers Insurance policy denied plaintiff benefits citing an exclusion in its policies for employee accidents.  Plaintiff appealed to the N.Y. State Insurance Commission which upheld Travelers’ denial of coverage under the exclusion in the policy for injuries arising out of on-the-job accidents.  Plaintiff joined Travelers to his FELA case.

Travelers filed a Motion for Summary Judgment, citing the preemptive effect of the FELA which is the exclusive remedy for railroad employees injured in the course and scope of their employment.  The Court noted that the FELA is the exclusive remedy of railroad employees who are injured in the course and scope of their employment.  Because it is a federal law, the FELA preempts any state law which is in conflict with the FELA, such as state no-fault insurance laws.

Plaintiff’s counsel opposed the Motion for Summary Judgment by saying that although plaintiff had filed an FELA suit against Metro North, he should also be entitled to no fault disability benefits under the insurance policy in effect on the vehicle he was operating at the time of his accident.  The trial court disagreed.

The trial court held that Congress, in passing the FELA, intended to occupy the entire field of the rights and remedies of injured railroad workers which are exclusive to all other state court remedies.  As a matter of law, the trial court was unable to enforce plaintiff’s access to any other benefit programs for the same injuries or damages.  The trial court let stand the ruling of the N.Y. State Insurance Board’s decision affirming Travelers’ denial of benefits to the FELA plaintiff.



 

The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.
 

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Christopher J. Hoare
 
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