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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

Sabine Consolidated, Inc. v. State

This case addresses whether the federal Occupational Safety and Health Act (OSHA) preempts state criminal prosecution for criminally negligent homicide. Appellants Tantillo and Sabine Consolidated, Inc. were convicted in Texas after two employees died in a trench collapse, but the Court of Appeals reversed, citing OSHA preemption. This court examined express, implied, and conflict preemption doctrines. It concluded that OSHA does not preempt state criminal laws, as the federal act primarily aims to prevent workplace hazards, while state criminal statutes punish unlawful acts. The court reversed the Court of Appeals' judgment and remanded the case for consideration of remaining points of error.

OSHA preemptioncriminal negligent homicideworkplace safetystate criminal lawfederal preemptiontrench collapseemployee deathTexas Penal CodeOccupational Safety and Health ActSupremacy Clause
References
20
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
Nov 20, 1990

People v. Pymm

This case examines whether federal regulation of workplace safety under the Occupational Safety and Health Act (OSHA) preempts New York State's authority to criminally prosecute employers for conduct that results in unsafe working conditions. The corporate defendants, Pymm Thermometer Corporation and Pak Glass Machinery Corporation, along with their executives William Pymm and Edward Pymm, Jr., were convicted of various criminal charges, including conspiracy, assault, and reckless endangerment, stemming from severe mercury contamination at their Brooklyn facilities which caused neurological damage to an employee. The Trial Justice initially set aside the verdict, citing federal preemption, but the Appellate Division reversed this decision. The Court of Appeals affirmed the Appellate Division's ruling, concluding that OSHA does not expressly or impliedly preempt state criminal prosecutions for employer conduct, emphasizing that state criminal laws serve distinct purposes of punishment and deterrence beyond OSHA's regulatory standards.

PreemptionOSHAWorkplace SafetyCriminal ProsecutionMercury PoisoningEmployer LiabilityState LawFederal LawHazardous ConditionsCorporate Crime
References
24
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. MISSING
Regular Panel Decision

Sakellaridis v. Polar Air Cargo, Inc.

A plaintiff, employed by AOG Sheet Metal, Inc., suffered serious injuries after falling from a defective work platform on a Polar Air aircraft at John F. Kennedy International Airport. The plaintiff sued under New York Labor Law sections 240(1) and 241(6). The defendant, Polar, argued that federal statutes, including the Federal Aviation Act (FAA), the Airline Deregulation Act (ADA), and the Occupational Safety and Health Act (OSHA), preempted these state labor laws. The court rejected Polar's preemption arguments, finding that federal law does not override state worker protection statutes in this context. Consequently, Polar's motion for partial summary judgment was denied.

Federal PreemptionNew York Labor LawScaffold ActWorkplace SafetyAviation SafetyAirline Deregulation ActOccupational Safety and Health ActSummary Judgment MotionPersonal InjuryAircraft Maintenance
References
20
Case No. MISSING
Regular Panel Decision

Alcantara v. Allied Properties, LLC

Plaintiff-workers filed a lawsuit in New York state court alleging violations of the New York Displaced Building Service Workers Protection Act (NYDWPA) by new building owners. The plaintiffs sought restoration of their employment and back wages and benefits. The defendants removed the case to federal court, arguing that the state law claims were preempted by the National Labor Relations Act (NLRA) and the Labor Management Relations Act (LMRA). The court examined Garmon preemption, Machinists preemption, and Section 301 preemption. It concluded that none of these federal preemption doctrines provided a basis for removal to federal court. The court noted that the state court should be given the opportunity to construe the municipal law's provisions before federal intervention. Therefore, the plaintiffs' motion to remand the case to state court was granted.

Preemption DoctrineNLRA PreemptionLMRA PreemptionNYDWPAWorkers' Protection ActMotion to RemandFederal Question JurisdictionState Law ClaimsCollective BargainingLabor Law
References
30
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