Holloway v. Soo Line Railroad Co.

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-railroad employee’s action, alleging that defendant violated Federal Railway Safety Act (FRSA) by terminating him in retaliation for reporting his workplace injury. Fact that plaintiff’s termination occurred after his report of work-related injuries was insufficient by itself to establish violation of FRSA, and plaintiff otherwise failed to show that anyone in defendant’s management was frustrated with him for reporting workplace accident that formed substance of his protected conduct, or that management used his accident report as reason for terminating him. Also, record supported defendant’s explanation that termination was motivated by plaintiff’s multiple violations of work and safety rules, one of which occurred in plaintiff’s accident report. Fact that co-worker who was involved in same accident was not disciplined did not require different result, where plaintiff’s disciplinary history was greater than co-worker’s disciplinary history.