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Admiralty Law Keyed to Maraist
Monessen Southwestern Railway Co. v. Morgan
Citation:
486 U.S. 330, 108 S. Ct. 1837, 100 L. Ed. 2d 349 (1988)Facts
In August 1977, Morgan fell while alighting from a railroad car while working as a brakeman and conductor for Monessen Southwestern Railway, suffering a permanent back injury. He returned to work in February 1979 in the less physically demanding position of radio and supply clerk. Morgan brought an FELA action in Pennsylvania state court, alleging his fall was due to the railroad’s negligence and claiming his future earning power was impaired because he could not obtain certain incentive and shift differential payments in his new position. At trial, the judge refused to instruct the jury to discount future damages to present value, instead applying Pennsylvania’s “total offset” rule which presumes future inflation equals future interest rates. The jury awarded Morgan $125,000, and the trial judge added $26,712.50 as prejudgment interest under Pennsylvania Rule 238. The railroad appealed, arguing that both the prejudgment interest award and the failure to instruct on present value were improper in FELA cases.
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