Armstrong v. BNSF Railway Co.

Federal 7th Circuit Court
Civil Court
Federal Rail Safety Act
Citation
Case Number: 
Nos. 16-3674 & 17-1088 Cons.
Decision Date: 
January 18, 2018
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

In action under Federal Rail Safety Act (FRSA) arising out of claim that plaintiff-employee was terminated in retaliation for reporting work-related injury, Dist. Ct. did not err in giving instruction that informed jury that defendant could not be held liable under FRSA if it concluded that defendant terminated plaintiff based on its honestly held belief that plaintiff had not engaged in protected activity under FRSA in good faith. Instant instruction was accurate statement of law, and Ct. rejected plaintiff’s claim that instruction implied that he was required to prove that defendant had improper retaliatory motive. Moreover, videotape supported management’s claim that plaintiff had lied in his assertion that his supervisor had caused plaintiff’s injuries to his leg. Also, Dist. Ct. could properly award defendant its costs as prevailing party under Rule 54(d)(1), even though FRSA does not expressly grant said costs to prevailing employers.