Koziara v. BNSF Railway Co.

Record failed to contain sufficient evidence to support jury’s verdict in favor of plaintiff-railroad worker in action under Federal Railroad Safety Act, alleging that defendant-employer terminated plaintiff in retaliation for reporting work-related injury. Employer stated that plaintiff was fired for being careless at time of accident and for theft, and record supported defendant’s contention where, prior to plaintiff’s termination, defendant had conducted investigation of accident and learned that: (1) plaintiff had been careless at time of accident; and (2) plaintiff had taken certain railroad ties without authority, which was against company rules. Fact that plaintiff’s injury report initiated investigation into events that led to his termination did not constitute “proximate cause” of his termination, since filing of report itself had no legal significance. Record also failed to contain any evidence that defendant’s management was motivated by animosity regarding plaintiff’s filing of injury report, especially where cost of plaintiff’s injuries was insignificant.