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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

City of Austin v. Paxton

The City of Austin sued the State of Texas (Attorney General Ken Paxton and Texas Workforce Commission) to enjoin Texas Local Government Code § 250.007(c). This state law allows landlords to refuse tenants using federal housing vouchers, which the City argues is preempted by federal law due to its ordinance prohibiting such discrimination. The State filed a motion to dismiss, citing lack of subject matter jurisdiction and failure to state a claim. The Court denied the dismissal for lack of jurisdiction, affirming the City's standing and ruling the suit not barred by the Eleventh Amendment. However, the Court granted dismissal for the City's conflict preemption and Section 3617 express preemption claims, but denied dismissal for the Section 3615 express preemption claim, concluding the City adequately pleaded a disparate impact claim.

PreemptionFederal Housing Choice Voucher ProgramTexas Local Government CodeFair Housing ActEleventh AmendmentStandingMotion to DismissDisparate ImpactCity OrdinanceState Law
References
37
Case No. MISSING
Regular Panel Decision

Henderson v. National Railroad Passenger Corp.

Plaintiff Nathaniel Henderson sued National Railroad Passenger Corporation d/b/a Amtrak under the Federal Employers Liability Act (FELA) for injuries sustained after being struck by a train due to alleged negligence. Amtrak filed a motion in limine to preclude Henderson from presenting evidence related to negligence claims, arguing they were preempted by the Federal Railroad Safety Act (FRSA). The Court, relying on the Supreme Court's decision in POM Wonderful LLC v. Coca-Cola Co., denied Amtrak's motion. The ruling clarified that the FRSA's preemption clause applies only to state laws, not federal claims under FELA, and that the two federal statutes complement each other.

FELA ClaimsFRSA PreemptionRailroad NegligenceFederal Statutory ConflictIn Limine Motion DenialRoadway Worker SafetyStatutory InterpretationFederal Common LawWorker InjurySupreme Court Guidance
References
22
Case No. MISSING
Regular Panel Decision
Jun 09, 1999

Longo v. Metro-North Commuter RailRoad

A plaintiff, a Metro-North employee with flagging duties on a construction site managed by Yonkers Contracting Company, sustained injuries after falling through a hole. The Supreme Court initially denied the plaintiff's summary judgment motion on Labor Law claims and granted Yonkers' cross-motion to dismiss these claims. On appeal, the order was modified; the appellate court reinstated the Labor Law claims against Yonkers, ruling the plaintiff was an integral part of the construction crew entitled to statutory protection. However, the court granted summary judgment to Metro-North, dismissing the plaintiff's Federal Employers' Liability Act (FELA) claim due to federal preemption. The decision emphasized that Labor Law violations cannot form part of a FELA action.

Workers' CompensationConstruction Site AccidentLabor Law 240Labor Law 241Labor Law 241-aLabor Law 200Federal Employers' Liability ActFederal PreemptionSummary JudgmentAppellate Review
References
8
Case No. MISSING
Regular Panel Decision

Empire Blue Cross & Blue Shield v. Consolidated Welfare Fund

Empire Blue Cross and Blue Shield (Empire) sued the Consolidated Welfare Fund and other defendants for breach of contract, fraud, and RICO violations. The defendants moved for partial judgment on the pleadings, asserting that the state law claims were preempted by ERISA. The court analyzed whether the Fund qualified as an 'employee welfare benefit plan' (EWBP) under ERISA. Finding that the Fund, with its 'associate members' from diverse backgrounds and commercial solicitation, did not meet the criteria of an EWBP, the court concluded that ERISA preemption did not apply. Therefore, the defendants' motion for partial judgment on the pleadings was denied, allowing Empire's state law claims to proceed.

ERISA PreemptionEmployee Welfare Benefit PlanHealth Insurance FraudLabor Union MembershipAssociate MembersRule 12(c) MotionFederal Civil ProcedureStatutory InterpretationCommercial Insurance SchemesDistrict Court Ruling
References
11
Case No. MISSING
Regular Panel Decision

McDonald v. City of New York

The plaintiff sustained personal injuries while working on a dry dock at the Brooklyn Navy Yard. The Supreme Court initially denied the defendants' motions for summary judgment, asserting the case did not fall under admiralty jurisdiction. On appeal, the higher court reversed this finding, concluding that a maritime nexus and situs existed, thus invoking substantive maritime law. This preemption by federal maritime law rendered the strict liability provisions of New York Labor Law §§ 240 and 241 inapplicable. Consequently, the appellate court granted the defendants' motions to dismiss claims based on these labor laws, while affirming the denial of dismissal for claims under common law negligence and Labor Law § 200.

Admiralty JurisdictionMaritime LawLabor LawPreemptionPersonal InjuryDry DockSummary JudgmentAppellate CourtNew YorkNegligence
References
18
Case No. MISSING
Regular Panel Decision

Romney v. Lin

This opinion addresses an action to collect unpaid contributions owed by Goodee Fashions, Inc. to four union benefit funds, totaling $70,647.17. After an initial judgment against Goodee Fashions proved uncollectible, the plaintiff, representing the union benefit funds, sued Alan Lin, a principal shareholder, under New York Bus. Corp. Law § 630. This state law holds the ten largest shareholders jointly and severally liable for debts to employees, including benefit funds. Defendant removed the case to federal court, arguing preemption by ERISA and LMRA. The court denied the plaintiff's motion to remand and granted the defendant's motion to dismiss, ruling that N.Y. Bus. Corp. Law § 630 is preempted by ERISA. Consequently, the claim for $70,647.17 was dismissed, except for a $598.27 portion related to the Sportswear Industry Trust Fund, which was deemed not an ERISA fund.

ERISA PreemptionLMRAShareholder LiabilityUnpaid ContributionsEmployee Benefit PlansCollective BargainingState Law PreemptionFederal JurisdictionCorporate DebtDismissal
References
11
Case No. MISSING
Regular Panel Decision

Carlisle v. Philip Morris, Inc.

This appeal addresses whether the Federal Cigarette Labeling and Advertising Act preempts state common-law tort claims for smoking-related injuries and deaths. Plaintiffs, including individual smokers and widows of deceased smokers, alleged various tort claims like failure to warn, design defects, misrepresentation, and civil conspiracy against cigarette manufacturers. The trial court initially granted summary judgment for the defendants based on preemption. The appellate court reversed, concluding that the Labeling Act does not clearly or unambiguously intend to preempt such common-law claims. The court highlighted the speculative nature of the conflict, the Act's primary goal of public health information, the lack of alternative remedies, and legislative history.

PreemptionFederal Cigarette Labeling and Advertising ActCommon-Law TortSmoking InjuriesProduct LiabilityFailure to WarnDesign DefectsMisrepresentationCivil ConspiracyState Law
References
83
Case No. 21-0769
Regular Panel Decision
Jun 28, 2024

The Kansas City Southern Railway Company v. Angela Horton and Kevin Houser

This is a concurring opinion by Justice Busby of the Supreme Court of Texas concerning the preemption of state common-law negligence suits against railway companies. The core issue is whether the Interstate Commerce Commission Termination Act (ICCTA) grants exclusive jurisdiction to the Surface Transportation Board (STB) over humped railroad crossings, thereby preempting state claims. Justice Busby joins the Court's opinion, which concludes that such preemption does not occur. The opinion extensively criticizes the current implied obstacle preemption doctrine for being inconsistent with the Supremacy Clause and argues for a "logical contradiction" test grounded in originalism. Furthermore, Justice Busby contends that applying current implied obstacle preemption in this context conflicts with the major questions doctrine, which requires clear congressional authorization for significant shifts in federal and state power. The opinion highlights the unworkable and inconsistent application of existing preemption jurisprudence and concludes that the plaintiffs' common-law negligence claims are not impliedly preempted by ICCTA.

PreemptionFederalismSupremacy ClauseInterstate Commerce Commission Termination Act (ICCTA)Surface Transportation Board (STB)Major Questions DoctrineState Common LawRailroad SafetyNegligenceStatutory Interpretation
References
89
Case No. W2007-00436-COA-R3-CV
Regular Panel Decision
Jan 15, 2009

Thomas David Jordan v. Burlington Northern Santa Fe Railroad Company, A Corporation, and Norfolk Southern Railway Company, A Corporation

Thomas David Jordan, a Norfolk Southern Railway employee, sustained severe injuries when he was struck by a Burlington Northern Santa Fe Railway train while performing duties between tracks. Jordan initiated a Federal Employers' Liability Act (FELA) lawsuit against Norfolk Southern and a common law negligence claim against Burlington Northern. A jury awarded Jordan $4 million, finding Norfolk Southern 100% at fault. On appeal, the Court of Appeals of Tennessee affirmed the jury's verdict, rejecting arguments about state statute preemption, jury instructions on causation, and the excessiveness of damages. However, the court reversed the trial court's decision regarding an inter-railroad Letter Agreement, ruling that Norfolk Southern must indemnify Burlington Northern for its defense costs related to the claim.

FELA claimRailroad employee injuryInter-railroad liabilityNegligence causationFederal preemptionJury damage awardIndemnity contract disputeTrack clearance safetyWorkplace accidentAppellate procedure
References
94
Case No. 09-23-00203-CV
Regular Panel Decision
Jun 19, 2025

Jermaine Thomas v. Iron Horse Terminals, L.L.C.

Jermaine Thomas appealed a summary judgment granted in favor of Iron Horse Terminals, L.L.C. (IHT). Thomas, a train conductor, was injured while working for IHT and sought remedies under the Federal Employers’ Liability Act (FELA), alleging IHT was a common carrier. IHT denied FELA applicability, arguing it was a workers' compensation subscriber and not a common carrier. The appellate court affirmed the trial court's decision, finding that IHT did not meet the criteria of a common carrier under FELA, specifically lacking common ownership with a railroad, contractual relationship for common carrier functions, and remuneration from a common carrier. Consequently, Thomas's FELA claim was not applicable.

FELACommon CarrierSummary JudgmentWorkers' CompensationInterstate CommerceRail ServiceEmployer LiabilityTexas LawAppellate ReviewLone Star Factors
References
13
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