Dykes v. Norfolk & Western Railway Co.

The plaintiff, Ralph Dykes, was injured while setting the hand brake on one of his employer’s locomotives. He brought this action against the employer, Norfolk and Western Railway Company, alleging a violation of the Safety Appliance Acts (45 U.S.C. secs. 1 through 16 (1982)), and he was awarded $18,000 in compensatory damages following a jury trial in the circuit court of Madison County. The appellate court, with one justice dissenting, reversed the judgment. (123 Ill. App. 3d 1.) The court held that locomotives are not required by the Safety Appliance Acts to be equipped with hand brakes…