Norfolk Southern Ry. Co. v. Evans, [Ms. A25A1180, Aug. 19, 2025] __ Ga. App. __ (2025). The court (Mercier, J.; Dillard, P.J., and Senior Judge C. Andrew Fuller, concur) reverses the denial of summary judgment in favor of Norfolk Southern in a Federal Employers’ Liability Act (FELA) action, holding that Plaintiff failed to present competent medical expert testimony on specific causation.
Although FELA applies a relaxed causation standard, plaintiffs must still present admissible evidence linking their injuries to employer negligence. Ms.* 4 (quoting Smith v. CSX Transp., 806 S.E.2d 890 (2017)). Plaintiff’s treating physician expressly declined to offer an opinion on causation, and a biomechanical engineer’s general ergonomic testimony was insufficient to meet the burden. Ms. *5 (quoting Bowers v. Norfolk S. Corp., 537 F. Supp. 2d 1343, 1377 (M.D. Ga. 2007)). Without medical causation evidence, the FELA claim failed as a matter of law, and the Court reverses the denial of Norfolk Southern’s motion for summary judgment.