CSX Transportation, Inc. v. Healey
861 F.3d 276
| 1st Cir. | 2017Background
- In 2014 Massachusetts enacted the Massachusetts Earned Sick Time Law (MESTL), requiring employers with ≥11 employees to provide up to 40 hours/year of paid sick time for specified reasons, including an employee's own illness.
- Interstate rail carriers operating in Massachusetts challenged enforcement, seeking declaratory judgment that the MESTL is preempted by the Railroad Unemployment Insurance Act (RUIA) and alternatively by the Railway Labor Act (RLA) or ERISA.
- The RUIA (originally 1938; sickness benefits added 1946) requires carriers to fund a federal sickness-benefits scheme (partial wage replacement after the 4th consecutive day of sickness) and contains an express preemption clause declaring federal provision of sickness benefits "exclusive."
- The district court granted summary judgment for the carriers, holding that RUIA preempted the MESTL in its entirety as applied to those carriers; the state Attorney General and union intervenors appealed.
- The First Circuit analyzed whether MESTL §148C(c)(2) (paid leave for an employee’s own illness) provides "sickness benefits under a sickness law of any State" within the meaning of 45 U.S.C. §363(b).
- The court concluded RUIA preempts at least subsection (c)(2) of the MESTL as applied to interstate rail carriers and remanded for the district court to consider (and resolve) whether other parts of MESTL remain applicable or are preempted by RUIA, RLA, or ERISA and whether severance is appropriate.
Issues
| Issue | Plaintiff's Argument (Carriers) | Defendant's Argument (AG/Unions) | Held |
|---|---|---|---|
| Whether RUIA preempts MESTL §148C(c)(2) (paid leave for employee’s own sickness) | RUIA preempts state-mandated sickness benefits for railroad employment; federal scheme is "exclusive." | MESTL paid sick time is not the same as RUIA "sickness benefits" and thus falls outside §363(b). | RUIA preempts MESTL §148C(c)(2) as applied to interstate rail carriers. |
| Whether "sickness benefits" in RUIA should be read narrowly (only RUIA-defined money payments for "days of sickness") | N/A (plaintiffs rely on ordinary reading that federal exclusivity covers state sickness mandates) | Term "sickness benefits" should be limited to the statutory/technical RUIA definition and exclude employer-paid sick leave. | Court rejects narrow textual restriction; ordinary and contextual readings support preemption. |
| Whether RUIA administrative materials (RRB guidance) exclude employer sick pay from "sickness benefits" | Carriers contend federal scheme and preemption are broad despite administrative notes. | RRB publications show RUIA benefits are distinct from employer sick pay, so preemption should be limited. | Court finds those publications describe benefit coordination but do not limit RUIA preemption. |
| Severability and remainder of MESTL (whether other provisions survive or are preempted by RUIA/RLA/ERISA) | Carriers sought complete relief; district court granted full relief below. | AG and unions argue severability; some sections may be applied to carriers. | Court remanded for district court to decide severability and whether other MESTL provisions are preempted (declined to decide in the first instance). |
Key Cases Cited
- In re Hill, 562 F.3d 29 (1st Cir. 2009) (ordinary-meaning presumption for undefined statutory words)
- Medtronic, Inc. v. Lohr, 518 U.S. 470 (1996) (consider purpose/context when construing express preemption)
- Tobin v. Fed. Exp. Corp., 775 F.3d 448 (1st Cir. 2014) (preemption to avoid patchwork regulation of interstate carriers)
- Danca v. Private Health Care Sys., Inc., 185 F.3d 1 (1st Cir. 1999) (ERISA preemption and uniformity concerns)
- Daboub v. Gibbons, 42 F.3d 285 (5th Cir. 1995) (preemption not to be easily circumvented by form changes)
- Cuomo v. Clearing House Ass'n, L.L.C., 557 U.S. 519 (2009) (weight of "plain terms" can render presumption against preemption immaterial)
- Yates v. United States, 135 S. Ct. 1074 (2015) (identical words may convey varying content in different statutory contexts)
- Wyeth v. Levine, 555 U.S. 555 (2009) (presumption against preemption principles)
- Lawson v. FMR LLC, 134 S. Ct. 1158 (2014) (headings are not a substitute for statutory text)