Metro-North Commuter Railroad Co. v. Jamey Murphy

The Federal Railroad Safety Act declares that “[l]aws, regulations, and orders related to railroad safety … shall be nationally uniform to the extent practicable.” 49 U.S.C. § 20106(a)(1). The Act empowers the Secretary of Transportation to “prescribe regulations and issue orders for every area of railroad safety.” Id. § 20103(a). And it expressly preempts state-law claims whenever the Secretary has prescribed a regulation “covering the subject matter of the State requirement.” Id. § 20106(a)(2). Pursuant to the Act, the Secretary has prescribed regulations providing criteria for determining the class of each track and fixing maximum operating speeds for each class. See 49 C.F.R. § 213.9. In CSX Transportation, Inc. v. Easterwood, this Court held that § 213.9 “should be understood as covering the subject matter of train speed with respect to track conditions.” 507 U.S. 658, 675 (1993). The Court accordingly concluded that the Act preempts state-law claims that a train “was traveling too quickly given the time and place.” Id. at 675 & n.15 (internal quotation marks omitted). The question presented is: Does the Federal Railroad Safety Act preempt a state-law claim that a train may not travel on a track next to a passenger platform at the operating speed set by 49 C.F.R. § 213.9?