opinion: DICE v. AKRON, CANTON & YOUNGSTOWN RAILROAD CO.
  No. 374.
  Argued December 3-4, 1951.
  Decided February 4, 1952.
  Rice A. Hershey argued the cause for petitioner; With him on the brief was Frederic O. Hatch.
  William A. Kelly argued the cause for respondent. With him on the .brief were Cletus G. Roetsel and Andrew P. Martin.
  Opinion of the Court by
  Mr. Justice Black,
  announced by Mr. Justice Douglas.
  Petitioner, a railroad fireman, was seriously injured when an engine in which he was riding jumped tjie track. Alleging that his injuries were due to respondent’s negligence, he brought this action for damages under the Federal Employers’ Liability Act, 35 Stat. 65, 45 U. S. C. § 51 et seq., in an Ohio court of common pleas. Respondent’s defenses were (1) a denial of negligence and (2) a written document signed by petitioner purporting to release respondent in full for $924.63. Petitioner admitted that he had signed several receipts for payments made him in connection witfijiis injuries but denied that he had made a full and complete settlement of all his claims. He alleged that the purported release was void because he had signed it relying on respondent’s deliberately false statement that the document was nothing more than a mere receipt for back wages.
  After both parties had introduced considerable evidence the jury found in favor of petitioner and awarded him a $25,000 verdict. The trial judge later entered judgment notwithstanding the verdict. In doing so he reappraised the evidence as to fraud, found that petitioner had been “guilty, of supine negligence” in failing to read the release, and accordingly held that the facts did not “sustain either in law or equity the allegations of fraud by clear, unequivocal and convincing evidence.” This judgment notwithstanding the verdict was reversed by the Court of Appeals of Summit County, Ohio, on the ground that under federal law, which controlled, the jury’s verdict must stand because there was ample evidence to support its finding of fraud. The Ohio Supreme Court, one judge dissenting, reversed the Court of Appeals’ judgment and sustained the trial court’s action, holding that: (1) Ohio, not federal, law governed; (2) under that law petitioner, a man of ordinary intelligence who could read, was bound by the release even though he had been induced to sign it by the deliberately false statement that it was only a receipt for back wages; and (3) under controlling Ohio law factual issues as to fraud in the execution of this release were properly decided by the judge rather than by the jury. 155 Ohio St. 185, 98 N. E. 2d 301. We granted certiorari because the decision of the Supreme Court of Ohio appeared to deviate from previous decisions of this Court that federal law governs cases arising under the Federal Employers’ Liability Act. 342 U. S. 811.
  First. We agree with the Court of Appeals of Summit County, Ohio, and the dissenting judge in the Ohio Supreme Court and hold that validity of releases under the Federal Employers’ Liability Act raises a federal question to be determined by federal rather than state law. Congress in § 1 of the Act granted petitioner a right to recover against his employer for damages negligently inflicted. State laws are not controlling in determining what the incidents of this federal right shall be. Chesapeake & Ohio R. Co. v. Kuhn, 284 U. S. 44; Ricketts v. Pennsylvania R. Co., 153 F. 2d 757, 759. Manifestly the federal rights affording relief to injured railroad employees under a federally declared standard could be defeated if states were permitted to have the final say as to what defenses could and could not be properly interposed to suits under the Act. Moreover, only if . federal law controls can the federal Act bp given that uniform application throughout the country essential to effectuate its purposes. See Garrett v. Moore-McCormack Co., 317 U. S. 239, 244, and cases there cited. Releases and other devices designed to liquidate or defeat injured employees’ claims play an important part in the federal Act’s administration. Compare Duncan v. Thompson, 315 U. S. 1. Their validity is but one of the many interrelated questions that must constantly be determined in these cases according to a uniform federal law.
  Second. In effect the Supreme Court of Ohio held that an employee trusts his employer at his peril, and that the negligence of an innocent worker is sufficient to enable his employer to benefit by its deliberate fraud. Application of so harsh a rule to defeat a railroad employee’s claim is wholly incongruous with the general policy of the Act to give railroad employees a right to recover just compensation for injuries negligently inflicted by their employers. And this Ohio rule is out of harmony with modern judicial and legislative practice to relieve injured persons from the effect of releases fraudulently obtained. See cases collected in note, 164 A. L. R. 402-415. See also Union Pacific R. Co. v. Harris, 158 U. S. 326; Callen v. Pennsylvania R. Co., 332 U. S. 625; Chesapeake & O. R. Co. v. Howard, 14 App. D. C. 262, aff’d, 178 U. S. 153; Graham v. Atchison T. & S. F. R. Co., 176 F. 2d 819. We hold that the correct federal rule is that announced by the Court of Appeals of Summit County, Ohio, and the dissenting judge in the Ohio Supreme Court — a release of rights under the Act is void when the employee is induced to sign it by the deliberately false and material statements of. the railroad’s authorized representatives made to deceive the employee as to the contents of the release. The trial court’s charge to the jury correctly stated this rule of law.
  Third. Ohio provides and has here accorded petitioner the usual jury trial of factual issues relating to negligence. But Ohio treats factual questions of fraudulent releases differently. It permits.the judge trying a negligence case to resolve ail factual questions ®f fraud “other than fraud in the factum.” The factual issue of fraud is thus split into fragments, some to be determined by the judge, others by the jury.
  It is contendéd that since a state may consistently with the Federal Constitution provide for trial of cases under the Act by a nonunanimous verdict, Minneapolis & St. Louis R. Co. v. Bombolis, 241 U. S. 211, Ohio may lawfully eliminate trial by jury as to one phase of fraud while allowing jury trial as to all other issues raised. The Bombolis case might be more in point had Ohio abolished trial by jury in all negligence cases including those arising under the federal Act. But Ohio has not done this. It has provided jury trials for cases arising under the federal Act but seeks to single out one phase of the question of fraudulent releases for determination’ by a judge rather than by a jury. Compare Testa v. Katt, 330 U. S. 386.
  We have previously held that “The right to trial by jury is ‘a basic and fundamental feature of our system of federal jurisprudence’ ” and that it is “part and parcel of the remedy afforded railroad workers under the Employers Liability Act.” Bailey v. Central Vermont R. Co., 319 Ü. S. 350, 354. We also recognized in that case that to deprive railroad workers, of the benefit of a jury trial where there is evidence to support negligence “is to take away a goodly portion of the relief which Congress has afforded them.” It follows that the right to trial by jury is too substantial a,part of the rights accorded by the Act to permit it to be classified as a mere “local rule of procedure” for denial in the manner that Ohio has here used. Brown v. Western R. Co., 338 U. S. 294.
  The trial judge and the Ohio Supreme Court erred in holding that petitioner’s rights were to be determined by Ohio law and in taking away petitioner’s verdict when, the issues of fraud had been submitted to the jury on conflicting evidence and determined in petitioner’s favor. The judgment of the Court of Appeals of Summit County, Ohio, was correct and should not have been reversed by the Supreme Court of Ohio. The cause is reversed and remanded to the Supreme Court of Ohio for further action not inconsistent with this opinion..
  It is-so ordered.
  The trial judge had charged the jury that petitioner’s claim of fraud must be sustained “by clear and convincing evidence,” but since the verdict was. for petitioner, he does not here challenge this charge as imposing too heavy a burden under controlling federal law.
instruction: What follows is an opinion from the Supreme Court of the United States. Your task is to determine the bases on which the Supreme Court rested its decision with regard to the legal provision that the Court considered in the case. Consider "judicial review (national level)" if the majority determined the constitutionality of some action taken by some unit or official of the federal government, including an interstate compact. Consider "judicial review (state level)" if the majority determined the constitutionality of some action taken by some unit or official of a state or local government. Consider "statutory construction" for cases where the majority interpret a federal statute, treaty, or court rule; if the Court interprets a federal statute governing the powers or jurisdiction of a federal court; if the Court construes a state law as incompatible with a federal law; or if an administrative official interprets a federal statute. Do not consider "statutory construction" where an administrative agency or official acts "pursuant to" a statute, unless the Court interprets the statute to determine if administrative action is proper. Consider "interpretation of administrative regulation or rule, or executive order" if the majority treats federal administrative action in arriving at its decision.Consider "diversity jurisdiction" if the majority said in approximately so many words that under its diversity jurisdiction it is interpreting state law. Consider "federal common law" if the majority indicate that it used a judge-made "doctrine" or "rule; if the Court without more merely specifies the disposition the Court has made of the case and cites one or more of its own previously decided cases unless the citation is qualified by the word "see."; if the case concerns admiralty or maritime law, or some other aspect of the law of nations other than a treaty; if the case concerns the retroactive application of a constitutional provision or a previous decision of the Court; if the case concerns an exclusionary rule, the harmless error rule (though not the statute), the abstention doctrine, comity, res judicata, or collateral estoppel; or if the case concerns a "rule" or "doctrine" that is not specified as related to or connected with a constitutional or statutory provision. Consider "Supreme Court supervision of lower federal or state courts or original jurisdiction" otherwise (i.e., the residual code); for issues pertaining to non-statutorily based Judicial Power topics; for cases arising under the Court's original jurisdiction; in cases in which the Court denied or dismissed the petition for review or where the decision of a lower court is affirmed by a tie vote; or in workers' compensation litigation involving statutory interpretation and, in addition, a discussion of jury determination and/or the sufficiency of the evidence.