Boyd v. BNSF Railway Co.
Annotate this CaseTerry Boyd filed this lawsuit against BNSF Railway Company, his former employer, under the Federal Employers’ Liability Act (FELA) after being injured in the course of his employment. Boyd later made a settlement offer, which BNSF rejected. The jury returned a verdict and award against BNSF. The district court ordered BNSF to pay double costs to Boyd pursuant to Minn. R. Civ. P. 68.03(b)(2), which provides for additional costs and disbursement incurred after an offer is rejected by a defendant and the relief awarded is less favorable to the defendant than the rejected offer. BNSF sought review, arguing that an award of double costs under Rule 68.03(b)(2) is preempted by FELA. The court of appeals affirmed. The Supreme Court reversed, holding that because double costs are substantive, rather than procedural, and are not authorized by federal law, FELA preempts the application of Rule 68.03(b)(2) in a state court FELA action.
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