Association of American Railroads v. Seggos
1:24-cv-00135
S.D.N.Y.Mar 3, 2025Background
- Plaintiffs are railroad and waste & recycling associations challenging the New York "Waste By Rail Law."
- The law requires specific coverings for solid waste transported by rail.
- Plaintiffs allege the law is unnecessary for public health and safety and argue it may be preempted by federal law.
- Defendants, officials from the NY Department of Environmental Conservation and the NY Attorney General, contend the law addresses legitimate rail safety concerns.
- Both sides agree discovery is unnecessary on whether the law relates to railroad safety but dispute the underlying facts.
- The court requests further submissions on whether factual disputes must be resolved or whether complaint allegations should be assumed true at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Waste By Rail Law relates to railroad safety | Coverings are unnecessary for public safety | Coverings prevent spillage and accidents, protecting railroad safety | Further submissions required |
| Preemption under federal law | State law is preempted by federal rail safety regulations | State law is valid; addresses issues not governed by federal regulation | No holding—court seeks briefing |
| Need to resolve factual disputes | Factual disputes are immaterial at this stage | Factual issues are material and must be addressed | Court requests party positions |
| Standard for motion to dismiss | Allegations should be viewed in light most favorable to plaintiff | Not directly addressed in excerpt | Briefing requested by court |
Key Cases Cited
- Merck Sharp & Dohme Corp. v. Albrecht, 587 U.S. 299 (2019) (factual disputes may be resolved as part of preemption legal question)
- Galper v. JP Morgan Chase Bank, N.A., 802 F.3d 437 (2d Cir. 2015) (relevant factual allegations are viewed in light most favorable to plaintiff on motion to dismiss)
- Island Park, LLC v. CSX Transp., 559 F.3d 96 (2d Cir. 2009) (court considered administrative fact findings about rail safety in preemption analysis)
- CSX Transp., Inc. v. City of Plymouth, Mich., 86 F.3d 626 (6th Cir. 1996) (court reviewed federal report to determine impact of local regulation on railroad safety)
- Iowa, Chi. & E. R.R. Corp. v. Washington Cnty., Iowa, 384 F.3d 557 (8th Cir. 2004) (safety component in state action relevant to preemption)