Worcester v. Springfield Terminal Railway Co.

BARRON, Circuit Judge.

Defendant, Springfield Terminal Railway Company (“Springfield”), appeals from a jury verdict awarding punitive damages to the plaintiff, Jason Worcester, under the whistleblower provisions of the Federal Railroad Safety Act (the “FRSA”). 49 U.S.C. § 20109. Springfield argues that the District Court gave the jury an incorrect instruction as to the standard for awarding punitive damages. We affirm.

I

On October 6, 2011, Springfield reported a leak of hydraulic fluid to the Maine Department of Environmental Protection. At that time, the plaintiff, Worcester, was an employee…