William Wheeler Thornton.

A treatise on the Federal employers' liability and safety appliance acts, and on the federal statutes on hours of labor, including Interstate commerce commission's rules and diagrams for equiments of cars online

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§286. Degree of diligence to make repairs.— What de-
gree of diligence is necessary in making repairs has been
variously decided. Thus, in one case it was said: "The
utmost diligence does not seem to have been used to discover
and repair the defect in this car.'' * In another case the court
said: **If diligence is to be recognized as a defense, certainly
it must be the highest form of diligence. Without regard to
what the rule of liability may be, the exercise of the greatest
care in the matter of equipment and maintenance will keep
coupling appliances in such condition as to exclude, except
in very remote instances, the necessity of prosecutions for the
enforcement of the act.'* The facts in this case, recited in
the opinion, show why the court did not think a proper de-

« United States v. Louisville, etc., R. Co. 166 Fed. Rep. 193.
418



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BBPAIBS. 419

gree of diligence had been observed to discover the defect and
repair it. The defect was occasioned by the loss of a clevis
pin. **The car came to the Indiana Harbor Road," said
Judge LandiSy ''from another carrier at a junction point.
Here the defendant maintained a car inspector, who testified
that, before cars were moved from there by his company, he
'customarily,' or 'usually,' or 'generally,' made an examina-
tion of the coupling apparatus, which examination consisted of
looking at the coupler and lifting the lever. If such inspec-
tion disclosed no defect, the inspector passed the car, other-
wise he made a record of the fact in a book kept for that
purpose, and the repairs were made before the car was moved.
The witness did not recall the particular car in question, but
his book contained no record of the car, which indicated that
his inspection showed the appliances to be in good condition.
Even assuming the government's view of the law^ to be
wrong, the finding in this case must be against the railway
company on the questions of fact. The distance traveled by
the car over defendant's track was but a few miles. If, at
the initial point, the pin had been in place and properly
fastened, it is not probable that it would have been displaced
by the ordinary handling of the car to destination. The
fact that the pin was missing at the end of the journey is
strongly indicative that the defect existed at the point of
origin, that is to say, that the pin either was not then present,
or was so badly worn or loosened, that proper inspection would
have disclosed the fact." The court, therefore, ordered a de-
cree entered against the railroad defendant thus found delin-
quent.*

««That it ig no defense to a JJO /«!• ^ y°i^ states v. Erie
prt>6ecutiDn of this character that R. C^- 166 I^ed. ^52] Chjcago A K

provide and mamUm its equip- ^~^ ' ^ 21 1 Fed. 448; United
ment with safety appliances, as g^^ ^ Kansas City Southern Ry.
required by the act." Co. 202 Fed. 828; 121 C. C. A. 136:

« United States v. Indiana Har- Chicago, B. A Q. R. Co. v. United
bor Co. 157 Fed. Rep. 666; see, States, 195 Fed. 241; 115 CCA. 193;
Also, United States v. Atlantic, United States v. Kansaa City South-
etc., R. Co. (Appendix G). em Ry. Co. 189 Fed 471.

The burden is upon the dfefend- It w not enough for a defense that
.nt to show an ^cuse for not ^^'^ ^^^^^J^^^^Z
making the repairs in time. United ^^ ^ j^ ^.j^^ ^^^^ XJnited

States V. IlUnois Central R. Co. g^^ ^ E^e R. Co. 167 Fed. 352;

United States v. Great Western Ry.

Co. 174 Fed. 399; Chicago, B. A Q.

Ry. Co. V. United States, 170 Fed.

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420 FEDERAL SAFETY APPLIANCE ACT.

§287. Use of diligence to discover defects— Want of
knowledge of defect. — ^If a railroad company has properly
equipped its ears, still it will be liable if they become de-
fective, thereby causing an injury ; and it is no defense that
the defendant company exercised reasonable care and dili-
gence to discover and repair the defect before placing the
car in service. **The statute says," said Justice Humphrey,
''that common carriers shall not haul or use cars in a certain
described condition. The defendant asks the court to hold,
in eflPect, that they cannot haul the car in that condition,
provided, that they have failed to use diligence to discover
its defective condition, but that if they have used due diU-
gence they may haul the car in its defective condition. In
all such cases it would be impossible for the oflBcers of the
government to determine in advance whether a statute has
been violated or not ; but before a prosecution could be prop-
erly instituted they should go to the defendant company,
ascertain what care it had used in regard to a certain car, de-
termine as a matter of fact and law whether the acts of the
defendant constituted due diligence, and from that determine
whether a prosecution might be safely instituted. It is evi-
dent that such a defense would take the very life out of the
act in question and render its enforcement impossible, except
in a few isolated cases. The courts cannot, by judicial legis-
lation, read into the act any language which will excuse of-
fenders any more than they can read into it language which
would increase their liability. Courts must enforce law as
they find it. * * * I have been unable to find that this
character of defense has been sustained in any case which
reached the courts of last resort. Counsel for defendant has
not cited any authority in support of this doctrine of due
diligence as a defense to a penal action. It is in the same
category with the question of intent under the revenue laws
and of good faith under statutes against handling adulterated
goods, drugs, etc. It is certainly well established that the
good intentions, or the lack of evil intent, on the part of a



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421



liquor dealer is no defense to a prosecution for the statutory
penalty. If this is no defense in a qtuisi criminal action,
it certainly would be none in a civil action involving the
same facts." **The propositions of law submitted by the de-
fendant are, therefore, denied.'** This case was approved in
a subsequent case in which it was said: '*The railroad com-
panies are charged, as I have shown, with the duty of haul-
ing only such cars as are provided with automatic couplers
in suitable i'epair, so as to be operative without the necessity
of employees going between the cars; and it would go far
to subvert the law and the purpose thereof if they were per-
mitted to say that they had no knowledge of the defect, and
that, therefore, they were not liable under the act. The com-
panies must ascertain for themselves and at their peril
whether or not they have taken up or are hauling cars with
defective couplers. Their intention to do right does not re-
lieve them.' I hold, therefore, that want of knowledge of the
defects on the part of the defendant company does not con-
stitute a defense."* Under the recent decisions knowledge



* United Steteg v. Southern Ry. Co.
135 Fed. Rep. 122.

* Citing United States v. Great
Northern Ry. Co. 150 Fed. 229.

•United Stotes v. Southern Pac.
Co. 154 Fed. Rep. 897; United States
V. Atlantic, etc., R. Co. 153 Fed. Rep.
918. This is now the rule of the
majority of the cases, especially those
of a recent date. United States v.
Atchison, etc., R. Co. 167 Fed. 636
(Appendix 0); United States v.
Wabash R. Co. 168 Fed. 1 (Appendix
G); United States v. Atchison, etc.,
Ry. Co. 163 Fed. Rep. 517; United
States y. Chicago, etc., R. Co. 163
Fed. Rep. 775; United States v.
Baltimore, etc., R. Co. (Appendix G);
United States v. Erie R. Co. 166 Fed.
Rep. 352; United States v. Southern
Ry. Co. 167 Fed. 699, Appendix G;
Atlantic Coast Line R. Co. v. United
States, 168 Fed. Rep. 175; United
States V. Atlantic Coast Line Co.
(Appendix G); Chicago, etc., R. Co.
V. United States, 165 Fed. Rep. 423;
Chicago, etc., R. Co. v. King, 169
Fed. Rep. 372. But see United
States V. UlinoiB Cent. R. Co. 170



Fed. 542 (Appendix G); Chicago, B.
A Q. Ry. Co. V. United States, 220
U. S. 559; 31 Sup. Ct. 619; 56 L. Ed.
65; Delk v. St. Louis A S. F. R. Co.
220 U. S. 580; 31 Sup. Ct. 617; 57
L. Ed. 590; United States v. Baltimore
& Ohio Ry. Co. 170 Fed. 456; United
States V. Southern Pacific Co. 169
Fed. 407; Chicago, B. A Q. Ry. Ck).
y. United States, 170 Fed. 556;
United States v. Southern Ry. Co.
170 Fed. 1014; Atchison, T. A S. F.
Ry. Co. V. United States, 172 Fed.
1021; Norfolk A W. Ry. Co. v. United
States, 177 Fed. 623; 101 C. C. A.
249; Johnson v. Great Northern Ry.
Co. 178 Fed. 643; Siegel v. New
York Central A H. R. R. Co. 178
Fed. 873; Galveston, H. A S. A. Ry.
Co. V. United Stetes, 183 Fed. 579;
Norfolk A W. Ry. Co. v. United
States, 191 Fed. 302; Nichols v.
Chesapeake A Ohio Ry. Co. 195 Fed.
913; Galveston, H. A S. A. Ry. Co.
V. United States, 199 Fed. 891;
United States v. Pere Marquette R.
Co. 211 Fed. 220; United States v.
Trinity A B. V. Ry. Co. 211 Fed. 448.



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422



FEDERAL SAFETY APPLIANCE ACT.



is not an element of the defense.*^ It therefore follows that
the use of diligence to discover and repair a defect is not
a defense.** But the exercise of such diligence on the part
of the carrier will, in a great measure, obviate occasion for
prosecutions.** A wilful intention on the part of carriers to
disregard the statutes is not an element of their violation.**
Inconvenience for the carrier to observe the statutes does
not excuse their violation.*** The duty to equip a car prop-
erly and repair it cannot be evaded by assignment or other-
wise.** But there is no violation of the statutes arising
from the failure of an employee to efficiently operate an
equipment, if it be actually operative.*^

§288. Duty to maintain car in repair is an absolute
one.* — ^Whether or not the duty of a railroad company to



"United States v. Chicago, etc.,
R. Co. 156 Fed. Rep. 180; United
States V. Philadelphia, etc., R. Co.
160 Fed. 696 (Appendix G); United
States V. Pennsylvania R. Co. (Appen-
dix G); United States v. Baltimore,
etc., R. Co. (Appendix G); United
States V. Lehigh VaUey R. Co. 160
Fed. 696 (Appendix G); United States
V. Chicago, etc., R. Co. 162 Fed. Rep.
775; United States v. Erie R. Co.
166 Fed. Rep. 352.

The inspectors of the government
are not required to notify the em-
ployees of the railroad company of
defects on cars. United States v.
Atchison, etc., R. Co. 167 Fed. 696:
Norfolk A W. Ry. Co. v. United
States, 191 Fed. 302; 112 C. C. A. 46;
Chicago, B. A Q. R. Co. v. United
States, 211 Fed. 12; 127 C. C. A. 438;
United States v. Chicago, G. W. Ry.
Co. 162 Fed. 775; United States v.
Baltimore & O. R. Co. 170 Fed. 466
(Appendix G); United States v.
Southern Ry. Co. (Appendix G).

* This section is retained, although
it is, in its main point, in direct
conflict with the rule laid down in the
next preceding section.

« Wabash R. Co. v. United States,
172 Fed. 864; United States v. South-



em Pacific Co. 169 Fed. 407; United
States v. Oregon Short Line R. Co.
180 Fed. 483; United States v. South-
em Ry. Co. 170 Fed. 1014; Chicago,
B. & Q. Ry. Co. V. United States,
170 Fed. 556; United States v. Balti-
more & Ohio R. Co. 170 Fed. 456.

** United States v. Indiana Har-
bor R. Co. 157 Fed. 565.

•* Chicago, B. A Q. Ry. Co. v.
United States, 170 Fed. 556; United
States V. Southem Pacific Co. 154
Fed. 897; United States v. Baltimore
A Ohio R. Co. 170 Fed. 456; Luken
V. Lake Shore A M. S. Ry. Co. 248
Dl. 377; 94 N. E. 175.

"Chicago Junction Ry. Co. v.
King, 169 Fed. 372; United States
v. Southem Pacific Co. 169 Fed. 407;
Siegel V. New York Central A H. R.
R. Co. 178 Fed. 873; United Stetes
V. Grand Tmnk Ry. Co. 203 Fed.
775; United States v. Pere Mar^
quette R. Co. 211 Fed. 220.

••Philadelphia A R. Ry. Co. 191
Fed. 1; Chicago Jimction Ry. Co. v.
King, 169 Fed. 372.

" United States v. Illinois Central
R. Co. 156 Fed. 182. But see Gilbert
V. Burlington, C. R. A N. Ry. Co.
128 Fed. 529.



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423



equip its cars with aiitomatfc couplers as the statute requires,
and to maintain them in that condition, is an absolute one
or one merely requiring the exercise of reasonable diligence,
has recently been settled by the Supreme Court of the
United States. Under the interpretation of this court given
the statute, reasonable diligence to equip cars with auto-
matic couplings and to maintain them in repair is not a
defense, either in an action to recover the penalty pre-
scribed by the statute for a failure in this respect or to
recover damages sustained by an employee by reason of
their defective condition. The court discussed at great
length Taylor's case.* In that case the court used this
language: **In the case before us the liability of the de-
fendant does not grow out of the common law duty of
master to servant. The Congress, not satisfied with the
common law duty and its resulting liability, has prescribed
and defined the duty by statute. We have nothing to do
but to ascertain and declare the meaning of a few simple
words in which the duty is described. It is enacted that *no
cars, either loaded or unloaded, shall be used in interstate
traffic which do not comply with the standard.' Theire is
no escape from the meaning of these words. Explanations
cannot clarify them, and ought not to be employed to con-
fuse them or lessen their significance. The obvious pur-
pose of the legislature was to supplant the qualified duty



•• St. Louis, I. M. & S. R. Co. v.
Taylor, 210 U. S. 281; 28 Sup. Ct.
616; 52 L. Ed. 1061. This case first
appeared as Neal v. St. Louis, I.
M. A S. R. Co. 71 Ark. 445; 78 S. W.
220, where it was reversed. It was
again appealed and the judgment



affirmed. St. Louis, I. M. k S. R. Co.
V. Neal, 83 Ark. 591; 98 S. W. 958.
And it was then appealed to the
United States Supreme Court, but
reversed 210 U. S. 281; 28 Sup. Ct.
616; 52 L. Ed. 1061.



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424 FEDERAL. SAFETY APPLIANCE ACT.

of the common law with an absolute duty deemed by it
more just. If the railroad does, in point of fact, use cars
which do not comply with the standard, it violates the plain
prohibition of the law, and there arises from that violation
the liability to make compensation to one who is injured by
it. It is urged that this is a harsh construction. To this
we reply that, if it be the true construction, its harshness is
no concern of the courts." In the first appeal, the Su-
preme Court of Arkansas had said: '*The statute upon
which this case is based does not say that the company shall
use ordinary care to provide its cars with drawbars of a
certain height, but it imposes as a positive duty upon rail-
way companies that they shall do so. * * * The act of
Congress requiring railroad companies to equip their cars
with drawbars of standard and uniform heights, specifically
provides that an employee injured by failure of a com-
pany to comply with the act shall not be deemed to have
assumed the risk by reason of his knowledge that the com-
pany had not complied with the statute, and there is no
question of assumed risk presented."**** The Federal Su-
preme Court, in this recent case regarded the Taylor case
as having settled that it was the absolute duty of an inter-
state railway company to maintain its cars, after their
equipment, in a proper condition, and that it was no defense
that it had used reasonable diligence to keep them in re-
pair.*** The court quoted with approval the following lan-
guage used by Mr. Justice Van Devanter (now on the
Federal Supreme Court Bench), used in a Circuit Court of
Appeals: *'It is now authoritatively settled that the duty of
the railway company in situations where the Congressional
law is applicable is not that of exercising reasonable care
in maintaining safety appliances in operative condition, but
is absolute. In that case the common law rules in respect

•bNeal V. St. Louis, I. M. & S. Sup. a. 612; 66 L. Ed. 621:

R. Co. 71 Ark. 446; 78 S. W. 220. Southern Ry. Co. v. United iStates,

«c Chicago, B. & Q. Ry. Co. v. 222 U. S. 20;j32 Sup. Ct. 2; 54 L. Ed.

United States, 220 U. S. 56©; 31 868.



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425



of the exercise of reasonable care by the master, and of the
non-liability by the master for the negligence of a fellow-
servant, were involved by the railway company, and were
held by the court to be superseded by the statute. * * *
While the defective appliance in that case*^ was a draw-
bar, and not a coupler, and the action was one to recover
damages for the death of an employee, and not a penalty,
we perceive nothing in these diflFerences which distinguish
that case from this. As respects the nature of the duty
placed upon the railway company, section five, relating to
drawbars, is the same as section two, relating to couplers;
and section six, relating to the penalty, is expressed in
terms which embrace every violation of any provision of
the preceding sections. Indeed, a survey of the entire
statute leaves no room to doubt that all violations thereof
are put in the same category, and that whatever property
would be deemed a violation in an action to recover for
personal injuries is to be deemed equally a violation in an
action to recover a penalty."*^ On the same day the Su-
preme Court settled the question holding it was the abso-
lute duty of a railway company to equip its cars as the
statute required and to so maintain them without regard to
reasonable care or the degree of diligence, it reaflSrmed the
rule it had approved.*^



«iThe Taylor case above re-
ferred to.

«2 United States v. Atchison, T.
& S. F. R. Co. 163 Fed. 617; 90
C. C. A. 327.

•sbelk V. St. Louis & S. F. R.
Co. 220 U. S. 580; 31 Sup. Ct.
617; 65 L. Ed. 690; reversing 170
Fed. 656; 96 C. C. A. 642; Vir-
ginia Rv. Co. V. United States, 223
Fed. 748.

The following cases in lower
courts had accepted the rule laid
down in the Taylor case and as
sulwequently affirmed by the Su-
preme Court: United States v.
Philadelphia & R. Rv. Co. 162 Fed.



403; United States v. Lehigh
Valley R. Co. 162 Fed. 410; United
States V. Denver & R. G. R. Co.
163 Fed. 519; 90 C. C. A. 329;
Chicago, M. & St. P. R. Co. 165
Fed. 423; 91 C. C. A. 371; 20
L. R. A. (N. S.) 473; Donegan
V. Baltimore & N. Y. R. Co. 165
Fed. 689; 91 C. C. A. 655; United
States V. Erie R. Co. 166 Fed. 352;
United States v. Wheeling & L. E.
R. Co. 167 Fed. 198, 201 ; Atlantic
Coast Line R. Co. v. United States,

168 Fed. 175, 184; 94 C. C. A. 35;
Chicago Junction R. Co. v. King,

169 Fed. 372, 377; 94 C. C. A.
6r>2; United States v. Southern



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426



FEDERAL SAFETY APPLIANCE ACT.



§289. Presnmptioii^-Diligeiice to discover defects and
make repairs in transit.* — ^Not at one are courts with
respect to the degree of diligence that must be exercised to
discover defects in cars and make repairs. In some of the
eases little or no excuse is accepted as a defense, even in a
criminal case; while in others more leniency is shown, at
least in criminal cases. Such a case is one that arose in the
United States Court for the District of Nebraska. In that
case the testimony showed that the defective car had at one
time been equipped in tlie manner required by law, and
the court declared that it could not presume that any part



Pac. Co. 169 Fed. 407, 409; 94 C. C.
A. 629; Watson v. St. Louis, I. M.
<& S. R. Co. 169 Fed. 942; Wabash R.
Co. V. United SUtes, 172 Fed. 864;
97 C. C. A. 284; Atchison, T. & S.
F. R. Co. V. United Stetes, 172 Fed.
1021; 96 C. C. A. 664; United States
V. Atchison, T. A S. F. R. Co. 163
Fed. 617; 90 C. C. A. 327; Norfolk
& W. R. Co. V. United States, 177
Fed. 623; 101 C. C. A. 249; United
States V. Illinois C. R. Co. 177 Fed.
801; 101 C. C. A. 16; Johnson v.
Great Northern R. Co. 178 Fed. 646;
102 C. C. A. 89; Siegel v. New York,
C. A H. R. R. Co. 178 Fed. 873;
Willett y. niinois Central R. Co.
122 Minn. 613; 142 N. W. 883;
NashviDe, C. A St. L. R. Co. v.
Henry, 168 Ky. 88; 164 S. W. 310;
St. Louis A S. F. R. Co. v. Conarty,
106 Ark. 421; 166 S. W. 93; Devine v.
Chicago A C. R. Co. 168 m. App. 460;
United States v. Pere Marquette
R. Co. 211 Fed. 220; Atlantic Coast
Line R. Co. v. Whitney, 62 Fla. 124;
66 Atl. 937; Chicago, B. A Q. Ry.
Co. V. United SUtes, 220 U. S. 669;
31 Sup. a. 612; 66 L. Ed. 682.

The fact that it may be incon-
venient for carrier to observe the
statutes does not excuse their viola-
tion. Chicago Junction Ry. Co. v.
King, 169 Fed. 372; 94 C. C. A. 662;
United States v. Southern Pacific
Co. 169 Fed. 407; 94 C. C. A. 629;
Siegel V. New York Central A H. R.
R. Co. 178 Fed. 873; United Stetes
V. Grand Trunk Ry. Co. 203 Fed.
776: United Stetes v. Pere Marquette
R. Co. 211 Fed. 220.

Li the following cases the same rule
was adopted: Chicago, B. A Q. Ry.



Co. v. United Stetes, 170 Fed. 556;
United Stetes v. Dlinois Central R.
Co. 170 Fed. 642; United Stetes v.
Philadelphia A R. Ry. Co. 160 Fed.
696; United Stetes y. Southern Pacific
Co. 167 Fed. 699; United Stetes v.
Louisville A N. R. Co. 166 Fed. 193;
Brinkmeir v. Missouri Pacific Ry.
Co. 81 Kan. 101; 106 Pac. 221; 224
U. S. 269; 32 Sup. a. 412; 66 L.
Ed. 768, overruling first paragraph
of syllabus in Missouri Pacific Ry.
Co. V. Brinkmeir, 77 Kan. 14; 93
Pac. 621.

Reasonable diligence to discover
defect is all that is necessary to be
used has been held in these cases:
Norfolk A W. Ry. Co. v. Haaelrigg,
170 Fed. 661; United Stetes v.
niinois Central R. Co. 166 Fed. 182;
United Stetes v. Rlinois Central R
Co. 170 Fed. 642; Carson v. Southern
Ry. Co. 68 S. C. 66; 46 S. E. 625;
see St. Louis, I. M. A S. Ry. Co. v.
York, 92 Ark. 664; 123 S. W. 376.

The same degree of diligence is
required under the Michigan stetute.
Wight V. Michigan Central R Co.
161 Mich. 216; 126 N. W. 414; 17
Det. Leg. N. 289. and under the
niinois stetute, Erlinger v. St. Louis
A O. Ry. Co. 162 HI. App. 640; 245
ni. 304; 92 N. E. 163.

In the construction of a stete
stetute regulating intrastete cars in
terms identical with the Federal
stetute concerning the duty to equip
and keep couplers in repair, the stete
court will follow the construction
placed upon the Federal stetute.
Luken v. Lake Shore A M. S. Ry. Co.
248 m. 377; 94 N. E. 176.



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REPAIRS. 427

of the required equipment was imperfect when the alleged
defective cars had, some time previously to the discovery of
the defects, been started on their interstate journeys, for there
was no evidence whatever as to the effect that the safety ap-
pliances were in any wise defective when they be|?an their
journey. "The presumption of innocence,** said the court,
"will leave no room for the inference that the cars were not
properly equipped when that journey was bejrun, especially
as no intelligent person can shut his eves to the fact that the
rapid motion, rough jostling and jolting of the trains, and
their immense weight may at some time result in injury to
such equipment. There cannot be much nicety in the move-
ments of freight trains. The only offenses," continued the
court, "imputed to the defendant in these cases is the use of
the various cars at the times specified in the pleadings and
covered by the evidence. Except these, no other offenses are
charged or attempted to be proved. The testimony on behalf
of the government shows that nearly every one of the cars
had started from the initial point of their respective jour-
neys at least one day, and usually longer, before the inspectors
of the United States discovered the defects at some inter-
mediate station. The testimony was very brief, and was di-
rected altogether to what the inspectors then saw. No
information was given which might enable the court to deter-
mine how long the defect existed. Obviously, under these
circumstances, we could not conclude that any defects existed
when the car started several days before. We must, on the
contrary, presume that the defects were in some way caused
during the long previous journey from the initial point to
the point of discovery, and therefore, presuming that no vio-
lation of the act occurred until after the cars had left the
original starting points, and having ascertained from the clear
and explicit evidence offered by the United States that de-
fects were found during the subsequent journey, we come to
the point where our greatest difficulty begins. We should



Online LibraryWilliam Wheeler ThorntonA treatise on the Federal employers' liability and safety appliance acts, and on the federal statutes on hours of labor, including Interstate commerce commission's rules and diagrams for equiments of cars → online text (page 53 of 102)