CSX Transportation, Inc. v. Easterwood
507 U.S. 658 (1993)
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Rule of Law:
The Federal Railroad Safety Act of 1970 (FRSA) preempts state common law negligence claims based on excessive train speed when a train is operating within federally prescribed speed limits. However, FRSA does not preempt state negligence claims for inadequate warning devices at a grade crossing unless federal funds have participated in the installation of the warning devices at that specific crossing.
Facts:
- The Georgia Department of Transportation (DOT) undertook a project to improve several railroad crossings in Cartersville, Georgia.
- As part of this project, the DOT installed motion-detection circuitry at the Cook Street crossing.
- The DOT planned to install a crossing gate at Cook Street, and federal funds were allocated for it.
- The city of Cartersville declined to approve the construction of a traffic island necessary for the gate's installation.
- Consequently, the gate was never installed at Cook Street, and the allocated federal funds were transferred to other projects.
- On February 24, 1988, a train owned and operated by CSX Transportation, Inc., collided with a truck driven by Thomas Easterwood at the Cook Street crossing.
- The train was traveling at a speed below the maximum 60 miles per hour limit set by federal regulations for that class of track.
- Thomas Easterwood was killed in the collision.
Procedural Posture:
- Lizzie Easterwood filed a diversity wrongful-death action against CSX Transportation, Inc. in the U.S. District Court for the Northern District of Georgia.
- CSX moved for summary judgment, arguing Easterwood's state law claims were preempted by FRSA.
- The District Court (trial court) granted summary judgment for CSX, holding that both the inadequate warning device claim and the excessive speed claim were preempted.
- Easterwood appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Court of Appeals (intermediate appellate court) affirmed the preemption of the excessive speed claim but reversed the preemption of the inadequate warning device claim.
- Both CSX and Easterwood petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Federal Railroad Safety Act of 1970 (FRSA) and its implementing regulations preempt state common law negligence claims against a railroad for (1) failure to maintain adequate warning devices at a grade crossing and (2) operating a train at an excessive speed?
Opinions:
Majority - Justice White
No as to the warning device claim; Yes as to the excessive speed claim. State law negligence claims are only preempted under the Federal Railroad Safety Act (FRSA) if a federal regulation 'covers the subject matter' of the state requirement. For warning devices, federal regulations at 23 CFR §§ 646.214(b)(3) and (4) do cover the subject matter, but only when federal funds 'participate in the installation of the [warning] devices.' Because federal funds were not ultimately used for the warning devices at the specific Cook Street crossing, the federal regulations do not apply, and the state law claim is not preempted. In contrast, the federal speed limit regulations at 49 CFR § 213.9(a) do 'cover the subject matter' of train speed. These regulations were adopted with safety concerns in mind and establish a comprehensive federal scheme, thus precluding state common law claims that a train's speed was excessive even when operating below the federal maximum. The 'local safety hazard' exception in § 434 does not apply because a general common law duty of care is not specific to an 'essentially local' hazard.
Concurring-in-part-and-dissenting-in-part - Justice Thomas
No as to the warning device claim; No as to the excessive speed claim. The majority is correct that the warning device claim is not preempted. However, the excessive speed claim should also survive preemption. The federal speed limit regulations in 49 CFR § 213.9(a) are based solely on track characteristics to prevent derailments and do not 'cover the subject matter' of train speed as it relates to grade crossing safety. The Secretary of Transportation explicitly declined to consider factors like population density when promulgating the rule. Therefore, because the federal government has not adopted a rule covering train speed for crossing safety, states remain free to enforce their common law duties requiring trains to operate at a reasonable and safe speed for the conditions of a particular crossing.
Analysis:
This decision clarifies the scope of FRSA's express preemption clause, establishing a bifurcated approach to common railroad negligence claims. For claims involving grade crossing warning devices, the ruling creates a bright-line test requiring a direct financial nexus: preemption exists only if federal funds were used for the devices at the specific crossing in question. For speed-related claims, the decision effectively immunizes railroads from state common law liability for excessive speed as long as they comply with federal regulations, treating the federal limits as both a ceiling and a floor for general negligence purposes. This forces future plaintiffs to frame speed-related claims more narrowly, such as a failure to slow for a specific, immediate hazard, rather than a general allegation that the train was traveling too fast for the conditions.
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