Leopoldo Mendoza-Gomez v. Union Pacific Railroad Company, Individually and Successor-in-Interest to Southern Pacific Transportation Company

The Federal Employers’ Liability Act (“FELA”), 45 U.S.C. § 51 et seq., expressly provides: Any contract, rule, regulation, or device whatsoever, the purpose or intent of which shall be to enable any common carrier to exempt itself from any liability created by this chapter, shall to that extent be void: *** 45 U.S.C. § 55. Despite this statutory language, this Court has held that railroads may settle claims and obtain a release from injured railroad workers “[w]here controversies exist as to whether there is liability, and if so for how much.” Callen v. Pennsylvania R. Co., 332 U.S. 625, 631 (1948). The question presented is: Whether a release of an “existing controversy” that also purports to exempt a railroad from future liability for legally distinct claims for diseases that have not yet manifested violates 45 U.S.C. § 55 with respect to those future claims.