Missouri Court of Appeals, Eastern District / May 29, 2018
Steven D. Ackman, Appellant, vs. Union Pacific Railroad Company, Respondent.
Steven D. Ackman sued Union Pacific Railroad Company under the Federal Employers' Liability Act (FELA) for cumulative back injuries allegedly sustained during his employment. The trial court granted summary judgment in favor of Union Pacific, concluding Ackman failed to present sufficient evidence of medical causation. The appellate court affirmed, holding that expert testimony is required to establish causation for cumulative injuries under FELA, and Ackman's medical records and affidavit were insufficient to create a genuine issue of material fact.