Supreme Court of the United States
Kurns v. Railroad Friction Products Corp.
February 29, 2012132 S. Ct. 1261
Summary
The Court held that state-law design-defect and failure-to-warn claims concerning locomotive equipment are preempted by the Locomotive Inspection Act (LIA) under the field preemption analysis in Napier. It rejected arguments that the LIA does not cover failure-to-warn claims or that the Federal Railroad Safety Act altered the preemption scope. Justice Sotomayor concurred in part regarding design-defect claims but dissented regarding failure-to-warn claims.