Csx Transportation, Inc. v. Easterwood (SCOTUS 1993)

Summary

The Court affirmed the Eleventh Circuit, holding that the Federal Railroad Safety Act and implementing regulations preempted Easterwood's excessive-speed negligence claim but not her inadequate-warning-device claim. Justice White explained that federal regulations must substantially subsume the subject matter of state law to preempt it. General crossing-safety regulations did not meet that standard, and the regulations specifying warning devices for federally funded installations did not apply to this crossing. Federal maximum-speed regulations, however, covered train speed in relation to track and crossing conditions. Justice Thomas, joined by Justice Souter, concurred in Parts I and II but dissented from Parts III and IV, reasoning that regulations based on track characteristics did not preempt state negligence claims addressing speed as a factor in crossing safety.

Holding

The standard for preemption under the Federal Railroad Safety Act.. State common-law duties fall within the Act's preemption provision, but federal regulations must substantially subsume the subject matter of the relevant state law rather than merely touch upon or relate to it.

Preemption of the inadequate-warning-device claim.. Easterwood's warning-device claim was not preempted. General highway-safety planning regulations and the Manual on Uniform Traffic Control Devices did not cover the relevant negligence duties, and the prerequisites for applying 23 CFR §§ 646.214(b)(3) and (4) were not established.

Preemption of the excessive-speed claim.. The federal maximum-speed regulations preempted Easterwood's claim that the train traveled at an excessive speed under the circumstances, even though its speed was below the federal maximum.

Csx Transportation, Inc. v. Easterwood

Summary

Holding

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