...statutory liability attempted to constrain that same process. Section 5 of the act declared void "any contract, rule, regulation, or device whatsoever,...exempt itself from any liability created by this Act." 150 In large part the section was directed at the railroad relief departments that compelled employees...

...title 49, is deemed to be a statute under sections 3 and 4 of this Act. (45 USC 54a) SEC. 5. That any contract, rule, regulation, or device whatsoever,...under or by virtue of any of the provisions of this Act, such common carrier may set off therein any sum it has contributed or paid to any insurance relief...

...Federal Employers Liability Act (FELA), passed in 1908. Section five of the statute provided that "any contract, rule, regulation, or device whatsoever,...created by this Act, shall to that extent be void." The framers made it clear that "relief association" contracts were included in the bar. A "proviso"...

...death of such employee. Sec. 54. Assumption of risks of employment In any action brought against any common carrier under or by virtue of any of the provisions of this chapter to recover damages for injuries to, or the death of, any of its employees, such employee shall...

...title 49, is deemed to be a statute under sections 3 and 4 of this Act. (45 USC 54a) SEC. 5. That any contract, rule, regulation, or device whatsoever,...under or by virtue of any of the provisions of this Act, such common carrier may set off therein any sum it has contributed or paid to any insurance relief...

...title 49, is deemed to be a statute under sections 3 and 4 of this Act. (45 USC 54a) Sec. 5. That any contract, rule, regulation, or device whatsoever,...under or by virtue of any of the provisions of this Act, such common carrier may set off therein any sum it has contributed or paid to any insurance relief...

...preexisting contracts. The Court pointed to language in the 1908 act that referred to any contract, "'the purpose or intent of which shall be to enable...exempt itself from any liability created by this Act.'" Those words, Justice Hughes wrote for the Court, did not "refer simply to an actual intent of the parties...

...title 49, is deemed to be a statute under sections 3 and 4 of this Act. (45 USC 54a) SEC. 5. That any contract, rule, regulation, or device whatsoever,...under or by virtue of any of the provisions of this Act, such common carrier may set off therein any sum it has contributed or paid to any insurance relief...

...of such employee. § 55. Contract, rule, regulation, or device exempting from liability; set-off Any contract, rule, regulation, or device whatsoever,...to exempt itself from any liability created by this chapter, shall to that extent be void: Provided, That in any action brought against any such common...

...of such employee. § 55. Contract, rule, regulation, or device exempting from liability; set-off Any contract, rule, regulation, or device whatsoever,...to exempt itself from any liability created by this chapter, shall to that extent be void: Provided, That in any action brought against any such common...