Napier v. Atlantic Coast Line Railroad
272 U.S. 605, 1926 U.S. LEXIS 42, 47 S. Ct. 207 (1926)
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Rule of Law:
The federal Locomotive Boiler Inspection Act, by granting comprehensive and general authority to the Interstate Commerce Commission to regulate all parts and appurtenances of locomotives, occupies the entire field of locomotive equipment regulation, thereby preempting states from enacting their own requirements on the subject.
Facts:
- Georgia enacted a statute requiring locomotives operating within the state to be equipped with an automatic door for the firebox.
- Wisconsin enacted a statute requiring locomotives operating within the state to be equipped with a protective cab curtain during winter months.
- The Georgia law specified the door's construction and operation, aimed at protecting the fireman's health and eyesight and improving safety.
- The Wisconsin law specified that the curtains must efficiently enclose the cab openings to protect the crew from weather, discomfort, and illness.
- Interstate railroad carriers operated locomotives in both Georgia and Wisconsin that were subject to the federal Boiler Inspection Act.
- The federal Interstate Commerce Commission (ICC), which had been delegated authority under the Boiler Inspection Act, had not issued any specific regulations concerning either automatic firebox doors or cab curtains.
Procedural Posture:
- In the Georgia case (No. 87), an interstate carrier sought an injunction in a federal district court to stop state officials from enforcing the automatic firebox door law.
- The federal district court granted the injunction in favor of the railroad.
- The state officials of Georgia then filed a direct appeal to the U.S. Supreme Court.
- In the Wisconsin cases (Nos. 310 and 311), interstate carriers sought an injunction in a Wisconsin state court to stop state officials from enforcing the cab curtain law.
- The Wisconsin trial court denied the injunction, and this judgment was affirmed by the Supreme Court of Wisconsin.
- The railroad carriers in the Wisconsin cases then brought the case to the U.S. Supreme Court on writs of error.
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Issue:
Does the federal Boiler Inspection Act occupy the entire field of regulating locomotive equipment so as to preclude Georgia and Wisconsin from enforcing state laws that require specific devices like automatic firebox doors and cab curtains on locomotives used in interstate commerce?
Opinions:
Majority - Mr. Justice Brandeis
Yes, the federal Boiler Inspection Act occupies the entire field of locomotive equipment regulation, precluding state legislation. The Act, as amended, delegates to the Interstate Commerce Commission a general and comprehensive power that extends to the design, construction, and material of every part of the locomotive and its tender. This broad delegation of authority demonstrates Congress's intent to establish a uniform national standard for locomotive equipment. The fact that the Commission has not yet exercised its authority to regulate a specific device is legally insignificant; the existence of the unexercised federal power is sufficient to preempt state laws on the same subject. Therefore, state requirements are precluded, regardless of their commendable purpose or whether they directly conflict with an existing federal rule.
Analysis:
This decision is a cornerstone of federal preemption doctrine, specifically illustrating "field preemption." The Court established that Congress can preempt state law not just by enacting conflicting statutes (conflict preemption), but by creating a regulatory scheme so pervasive and comprehensive that it implies an intent to occupy the entire legislative field. This ruling means that in areas of comprehensive federal regulation, states cannot supplement federal law, even if their regulations address different goals like employee health rather than direct operational safety. It reinforces the power of federal agencies and the importance of national uniformity in regulating instrumentalities of interstate commerce.
