BNSF Railway Company v. Seats, Incorporated
900 F.3d 545
| 8th Cir. | 2018Background
- BNSF settled a FELA suit by its locomotive engineer who was injured when his seat backrest broke; BNSF then sued Seats, Inc., the seat manufacturer, to recover settlement costs.
- Seats designed, manufactured, and warranted the seat; its contract with GE required compliance with the Locomotive Inspection Act (LIA).
- Seats moved to dismiss, arguing the LIA preempts BNSF’s state-law claims (products-liability and breach of contract) because the LIA occupies the field for locomotive equipment standards.
- The district court granted the motion to dismiss for lack of clear authority on preemption; BNSF appealed.
- The Eighth Circuit considered whether the LIA preempts (a) state common-law tort claims premised on violations of federal standards, and (b) contract claims enforcing voluntary promises to comply with the LIA.
Issues
| Issue | Plaintiff's Argument (BNSF) | Defendant's Argument (Seats) | Held |
|---|---|---|---|
| Whether the LIA preempts state-law products-liability claims that enforce federal standards of care | State enforcement of federal standards does not conflict with national uniformity; such claims are not preempted | LIA field preemption bars state claims touching locomotive design/materials | LIA does not preempt state tort claims based on violations of federal standards of care; dismissal was error |
| Whether the LIA preempts breach-of-contract claims that require compliance with the LIA | Contractual promises to comply with the LIA are self-imposed duties enforceable under state contract law | Such contract claims are effectively state regulation in disguise and thus preempted | Breach-of-contract claim is not preempted because it enforces a voluntarily assumed, contractual obligation |
| Whether enforcement under state law of a federal standard would undermine national uniformity | Enforcement merely vindicates the federal standard and does not impose conflicting operational rules on railroads | State enforcement would threaten the uniform federal regulatory scheme | Court held state enforcement does not inherently undermine national uniformity |
| Whether the district court should have addressed Seats’s other dismissal grounds | BNSF urged remand for further proceedings on other defenses | Seats asked for dismissal on all grounds | Court reversed dismissal and remanded remaining defenses to district court for initial consideration |
Key Cases Cited
- Urie v. Thompson, 337 U.S. 163 (Supreme Court 1949) (LIA supplies no private right; FELA provides remedy; LIA’s purpose is to ensure safe equipment)
- Napier v. Atlantic Coast Line R.R. Co., 272 U.S. 605 (Supreme Court 1926) (LIA intended to occupy field of locomotive design and material)
- Kurns v. Railroad Friction Prods. Corp., 565 U.S. 625 (Supreme Court 2012) (preemption bars state common-law duties addressing locomotive equipment)
- Delaware & Hudson Ry. Co. v. Knoedler Mfrs., Inc., 781 F.3d 656 (3d Cir. 2015) (state common-law claims based on federal equipment standards not preempted)
- Malone v. White Motor Corp., 435 U.S. 497 (Supreme Court 1978) (congressional purpose is the touchstone of preemption analysis)
- Baltimore & Ohio R.R. Co. v. Groeger, 266 U.S. 521 (Supreme Court 1925) (LIA prescribes definite, ascertainable standard of duty)
- Crane v. Cedar Rapids & Iowa City Ry. Co., 395 U.S. 164 (Supreme Court 1969) (nonemployees may pursue state common-law remedies for Safety Appliance Acts violations)
- American Airlines, Inc. v. Wolens, 513 U.S. 219 (Supreme Court 1995) (federal preemption does not bar enforcement of voluntarily assumed contractual obligations)
- Cipollone v. Liggett Grp., Inc., 505 U.S. 504 (Supreme Court 1992) (federal labeling law did not preempt state-law claims for breach of voluntary contractual commitments)