Union Pacific Railroad Co. v. Nami (Opinion)
Annotate this CasePlaintiff, an employee of Union Pacific Railroad, contracted West Nile virus from a mosquito bite. Plaintiff sued Union Pacific under the Federal Employers’ Liability Act (FELA) for failing to provide a safe workplace. The jury found that both Plaintiff and Union Pacific negligently caused his disease and attributed eighty percent responsibility to Union Pacific. The trial court rendered judgment on the verdict. Union Pacific appealed, arguing that under the common-law doctrine of ferae naturae, which limits a property owner’s liability for harm from indigenous animals that he has not attracted to the property, it owed Plaintiff no legal duty to protect him from mosquitoes. The Supreme Court reversed, holding that the doctrine of ferae naturae applied in this case and precluded Union Pacific’s liability.
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