Monohon v. BNSF Railway Co., No. 18-3346 (8th Cir. 2021)
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Plaintiff filed suit alleging that BNSF violated the Federal Rail Safety Act (FRSA) when it discharged him for reporting, in good faith, a hazardous safety condition. After the case proceeded to trial, the jury found in favor of plaintiff and awarded back pay. The district court denied plaintiff's request for reinstatement and instead awarded three years of front pay, thereafter granting BNSF's motion for judgment as a matter of law.
The Eighth Circuit concluded that BNSF's renewed motion for judgment as a matter of law was timely and therefore fell within Federal Rule of Civil Procedure 50(b)'s 28-day time period; there existed a legally sufficient evidentiary basis to support the jury's finding that plaintiff's report regarding the danger of wearing a seatbelt while hy-railing is a report of a hazardous safety condition; and the evidence was sufficient to support a finding that BNSF intentionally retaliated against plaintiff. Finally, the court concluded that the district court abused its discretion in granting BNSF's conditional motion for a new trial under Federal Rule of Civil Procedure 59. Accordingly, the court vacated the judgment in favor of BNSF, reversed the order granting BNSF's motion for judgment as a matter of law, and remanded for the reinstatement of the jury verdict and for the entry of such further relief.
Court Description: [Wollman, Author, with Colloton and Benton, Circuit Judges] Civil case - Federal Rail Safety Act. Judgment had not been entered as a matter of course under Fed. R. Civ. P. 58(c)(2), and defendant's renewed motion for judgment as a matter of law was timely; the district court erred in granting defendant's motion for judgment as a matter of law as there was a legally sufficient evidentiary basis to support the jury's findings that requiring an employee to wear a seatbelt while hy-railing was a hazardous safety condition and that defendant intentionally retaliated against plaintiff for reporting, in good faith, a hazardous safety condition; further, the district court abused its discretion in alternatively granting defendant a new trial on these facts; on remand, the district court should reconsider plaintiff's request for reinstatement.
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