BNSF Railway Company v. U.S. Dept. of Labor
Split Score
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Case Summary
Disposition
Vacated
The Eighth Circuit held that the Department of Labor’s order finding BNSF Railway liable for retaliatory discharge and awarding monetary and equitable relief violated BNSF’s Seventh-Amendment right to a jury trial. Concluding that the claim is legal in nature and does not fall within the public-rights exception, the court vacated the agency order and remanded.
Circuit Split Identified
Legal Issue
Whether statutory whistleblower retaliation claims under 49 U.S.C. § 20109 may be finally adjudicated by the Department of Labor without providing the defendant a jury trial under the Seventh Amendment.
Circuit Positions
Seventh Amendment entitles employers to a jury trial; Department of Labor may not finally adjudicate § 20109 retaliation claims seeking legal remedies.
Public-rights exception allows Department of Labor to adjudicate § 20109 retaliation claims without a jury trial.
Conflict Summary
The Eighth Circuit concluded that retaliatory-discharge claims seeking legal remedies must be tried before a jury because they are analogous to common-law causes of action and do not fit the public-rights exception, whereas the Second Circuit in Yellow Freight System, Inc. v. Martin held that such claims could be adjudicated administratively without a jury under the public-rights doctrine.