Supreme Court Decides Kurns v. Railroad Friction Products Corp.
On February 29, 2012, the U.S. Supreme Court decided Kurns v. Railroad Friction Products Corp., No. 10-879, holding that the Locomotive Inspection Act, 49 U.S.C. § 20701 et seq. preempted the plaintiffs' state law design-defect and failure-to-warn claims against a railroad carrier.
Plaintiff George Corson was employed as a welder and machinist by the Chicago, Milwaukee, St. Paul & Pacific Railroad for nearly 30 years, beginning in 1947. In 2005, Corson was diagnosed with mesothelioma. Two years later, in 2007, Corson and his wife filed suit in Pennsylvania state court against 59 defendants, including Railroad Friction Products Corporation, asserting state law design-defect and failure-to-warn claims. Railroad Friction removed the case to the Eastern District of Pennsylvania and moved for summary judgment, arguing that the plaintiffs' state law claims were preempted by the Locomotive Inspection Act. The district court granted the motion and the Third Circuit affirmed.
The Supreme Court affirmed the Third Circuit, holding that the plaintiffs' state law claims were preempted under the doctrine of field preemption. The Court addressed the plaintiffs' arguments in light of its prior decision in Napier v. Atlantic Coastline Railroad Company, in which the Court held that the Locomotive Inspection Act preempted a different state law claim because "[t]he federal and the state statutes are directed to the same subject—the equipment of locomotives." 272 U.S. 605 (1926). In light of this broad language, the Court rejected the plaintiffs' various efforts to distinguish Napier. The plaintiffs' claims, according to the Court, are both directly related to "the equipment of locomotives." Accordingly, because this is the field that the Locomotive Inspection Act occupies, the Court held that the plaintiffs' common law claims brought within this field were preempted.
Justice Thomas delivered the opinion of the Court in which Chief Justice Roberts and Justices Scalia, Kennedy, Alito, and Kagan joined. Justice Kagan filed a concurring opinion. Justice Sotomayor filed an opinion concurring in part and dissenting in part, in which Justices Ginsburg and Breyer joined.
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