327 F. Supp. 3d 260
D.D.C.2018Background
- Plaintiffs (CSX Transportation, CSX Intermodal, Amtrak, Springfield Terminal) are interstate rail employers who did not implement Massachusetts' Earned Sick Time Law (M.G.L. c.149, § 148C) because they contend it is preempted by federal law.
- The ESTL (effective July 1, 2015) requires eligible employees to accrue up to 40 hours/year of earned sick time (paid or unpaid) usable for personal illness, family care, medical appointments, and domestic violence-related needs.
- Plaintiffs sued the Massachusetts Attorney General seeking declaratory and injunctive relief, alleging preemption by the Railroad Unemployment Insurance Act (RUIA), the Railway Labor Act (RLA), and ERISA; the court bifurcated the litigation and litigated the RUIA claim first.
- The district court initially granted summary judgment to plaintiffs on RUIA preemption; the First Circuit affirmed in part, vacated in part, and remanded for further consideration of whether other ESTL provisions are preempted.
- On remand the parties stipulated there are no material factual disputes and filed renewed cross-motions for summary judgment focused on whether RUIA expressly preempts the remainder of the ESTL.
- The district court held that § 363(b) of the RUIA preempts the entirety of Massachusetts’ "earned sick time" scheme (including uses other than employees’ personal illness) and granted plaintiffs’ renewed motion for summary judgment on Count 1.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RUIA § 363(b) expressly preempts Massachusetts' ESTL "earned sick time" provisions | RUIA makes exclusive provision for "sickness benefits" and thus preempts all state "sickness laws" covering earned sick time, including family care, appointments, and domestic violence uses | ESTL's non-personal uses fall outside RUIA's intended scope; RUIA should be limited to personal sickness benefits similar to RUIA benefits | Held for plaintiff: § 363(b) preempts the entire ESTL earned-sick-time scheme as applied to interstate rail employers |
| Whether the statutory text or legislative history controls the scope of RUIA preemption | Text of § 363(b) is broad and dispositive; Congress used "sickness benefits" and "sickness law" without limiting language | Reliance on legislative history to narrow preemption to personal sickness, distinguishing benefits not similar to RUIA | Held for plaintiff: plain statutory text controls; legislative history cannot narrow an unambiguous preemption clause |
| Whether a narrow reading is required by presumption against preemption (historic state police powers) | Uniform federal scheme for railroad benefits justifies broad preemption to avoid patchwork regulation | ESTL addresses traditional state matters (family care, domestic violence), so presumption against preemption should apply to limit RUIA's reach | Held for plaintiff: congressional purpose of national uniformity and the unambiguous text overcome any presumption; broad preemption is necessary |
| Remedy: summary judgment and further claims | Plaintiffs sought summary judgment declaring RUIA preemption and enjoining enforcement | Defendant and unions sought summary judgment upholding ESTL provisions | Held for plaintiff: plaintiffs' renewed summary judgment on RUIA claim allowed; defendant and intervenors' cross-motions denied; court did not reach RLA/ERISA, dormant commerce, or severability issues |
Key Cases Cited
- Mesnick v. Gen. Elec. Co., 950 F.2d 816 (1st Cir. 1991) (summary judgment standard and purpose)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (materiality and genuine dispute standards for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden-shifting at summary judgment)
- Altria Group, Inc. v. Good, 555 U.S. 70 (U.S. 2008) (presumption against preemption when state police powers implicated)
- Lorillard Tobacco Co. v. Reilly, 533 U.S. 525 (U.S. 2001) (assessing scope of express preemption clauses)
- CSX Transp., Inc. v. Easterwood, 507 U.S. 658 (U.S. 1993) (statutory text as primary evidence of congressional intent on preemption)
- Mass. Delivery Ass'n v. Coakley, 769 F.3d 11 (1st Cir. 2014) (considering purpose and statutory scheme in preemption analysis)
- R.R. Ret. Bd. v. Duquesne Warehouse Co., 326 U.S. 446 (U.S. 1946) (background on RUIA origins)
- CSX Transp. v. Healey, 861 F.3d 276 (1st Cir. 2017) (First Circuit decision rejecting limiting RUIA preemption to benefits similar to RUIA)
- In re Larson, 513 F.3d 325 (1st Cir. 2008) (legislative history cannot override clear statutory text)
- Morales v. Trans World Airlines, Inc., 504 U.S. 374 (U.S. 1992) (need for uniform federal scheme supports preemption)
- Tobin v. FedEx Corp., 775 F.3d 448 (1st Cir. 2014) (preemption avoids patchwork regulation)
- Rowe v. New Hampshire Motor Transp. Ass'n, 552 U.S. 364 (U.S. 2008) (preemption to prevent state-level interference with federal objectives)
- National R.R. Passenger Corp. v. Su, 289 F. Supp. 3d 1130 (E.D. Cal. 2017) (contrasting district-court view narrowing RUIA preemption; declined persuasive weight)