Mark Spotted Horse v. BNSF Railway Co.Annotate this Case
Plaintiff, a machinist employed by the BNSF Railway Company (BNSF), brought this action against BNSF alleging negligence under the Federal Employers’ Liability Act (FELA). After his lawsuit was filed, Plaintiff requested the production of videos of the work area where the alleged injury occurred. BNSF refused to provide the video footage alleging that it had been overwritten. After a trial, the jury found in favor of BNSF. The Supreme Court reversed, holding that the district court abused its discretion when it (1) declined to impose a meaningful sanction on BNSF for its destruction of evidence; and (2) instructed the jury as to BNSF’s duty of care in a FELA action.