Locomotive Inspection Act Does Not Preempt Railroad Claims

The U.S. Court of Appeals for the Eighth Circuit held that the railroad’s claims against a manufacturer for a defective locomotive seat was not preempted by the Locomotive Inspection Act (“LIA”), 49 U.S.C. § 20701. After settling a personal injury claim with its employee who claimed the backrest of his locomotive seat was broken, the railroad initiated claims against the seat manufacturer to recover the amount of the settlement, expenses, and attorney fees. The railroad asserted multiple claims including breach of contract, product liability, strict liability, equitable subrogation, indemnity and contribution. The legal issue on appeal was whether the LIA preempted the railroad’s “products-liability claims based on federally-imposed standards of care.” The Court held it did not. The Court also held that the railroad’s breach of contract claim was not preempted by federal law. The case was remanded for further proceedings to the U.S. District Court of Nebraska.

BNSF Railway Company v. Seats, Incorporated, 900 F.3d 545 (8th Cir. 2018).