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Metro-North Commuter Railroad Co. v. Buckley

(1997)

Supreme Court of the United States - 521 U.S. 424

tl;dr:

Plaintiff was exposed to asbestos on the job and grew fearful of developing cancer; Court holds that Plaintiff cannot recover for his fear alone, without symptoms.

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ICRAIssue, Conclusion, Rule, Analysis for Metro-North Commuter Railroad Co. v. Buckley

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Facts & HoldingMetro-North Commuter Railroad Co. v. Buckley case brief facts & holding

Facts:Plaintiff Buckley worked for Defendant Metro-North as a pipe fitter....

Holding:The Supreme Court reversed.Relying on Gottshall, the Court noted that...

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Metro-North Commuter Railroad Co. v. Buckley | Case Brief DeepDive
Majority opinion, author: Justice Breyer
Level 1
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The Supreme Court reviewed a case involving a railroad worker seeking damages under FELA for emotional distress and medical monitoring costs due to asbestos exposure. The Court recognized FELA as a humanitarian law but limited liability to cases of negligence and physical impact. Recovery for emotional distress is generally limited to those with physical symptoms, and the Court is concerned about the validity of claims lacking objective medical proof. The Court is also considering whether a plaintiff without symptoms or disease can recover the economic cost of medical monitoring under FELA and is hesitant to endorse a traditional lump-sum damages remedy. The lack of evidence of emotional distress highlights the difficulty of separating valid claims from invalid or trivial ones. The Court will decide whether to reverse the Second Circuit's opinion on the issue of medical monitoring costs.

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Opinion (Concurring-in-part-and-dissenting-in-part), author: Justice Ginsburg
Level 1
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The case of Consolidated Rail Corporation v. Gottshall rejected a railworker's emotional distress claim due to lack of objective evidence, but upheld his claim for medical monitoring expenses for asbestos exposure. The employer did not inform or protect the workers against asbestos exposure until 1987, two years after the worker started working in the steam tunnels. The expenses are necessary for early detection and cure of any asbestos-related disease the worker may develop. The Supreme Court's reversal of the Second Circuit's decision on Buckley's second claim for medical monitoring costs is unclear. The author argues that recognizing a claim for medical monitoring under the FELA would align it with the evolving common law. However, the Supreme Court appears to place little value on these decisions in developing FELA law.

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