NJ Transit v. Colt
The Facts
Heffernan Colt, a New Jersey Transit employee, sustained injuries in a workplace accident and sued NJ Transit under FELA, which creates a federal cause of action for railroad workers injured on the job and abrogates contributory negligence defenses. NJ Transit moved to dismiss on the ground that, as an instrumentality of the State of New Jersey, it was entitled to Eleventh Amendment sovereign immunity from suit in federal court.
The Application
NJ Transit, as a state-owned entity operating a common carrier railroad in interstate commerce, voluntarily entered a federally regulated field where participation inherently conditions liability exposure under FELA; by accepting the statutory framework and commercial benefits of federal railroad law, it accepted the employee-injury obligations those laws impose. The Court rejected NJ Transit's attempt to partition its immunity—to accept federal regulation's advantages while rejecting its costs—holding that such voluntary entry into a regulated federal regime constitutes an effective waiver of Eleventh Amendment protection. Colt's injury claim therefore proceeded against the agency without the shield of sovereign immunity.
The Conclusion
The Supreme Court held that NJ Transit waived its Eleventh Amendment immunity by operating as a common carrier railroad subject to FELA. The agency could not selectively accept the benefits of federal railroad regulation while rejecting its employee-liability obligations.
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