CSX Transp., Inc. v. Easterwood

In CSX Transp., Inc. v. Easterwood, 507 U.S. 658 (1993), the widow of a truck driver killed in a railroad crossing collision brought a state law wrongful-death claim against the railroad. The United States Supreme Court held that FRSA's preemption clause barred the lawsuit to the extent it was based on an allegation that the railroad's train was traveling at an excessive speed. (Easterwood, supra, 507 U.S. at p. 661.) The Supreme Court determined the widow could not maintain her excessive speed claim because the Secretary of Transportation had promulgated regulations under FRSA setting maximum train speeds for certain classes of railroad track, thereby covering the subject matter of train speed with respect to track conditions, and the train was traveling within that speed limit. (Easterwood, supra, 507 U.S. at pp. 673-675.) The Supreme Court addressed the issue of FRSA preemption in a case involving a truck-train collision. The Plaintiff's husband was killed when his truck was hit by a train at a railroad crossing in Georgia. Id. at 1734. The Plaintiff brought a wrongful death action against the Defendant, CSX Transportation, alleging that CSX was negligent under Georgia law for "failing to maintain adequate warning devices at the crossing and for operating the train at an excessive speed." Id. The district court found both claims preempted under the FRSA; the Court of Appeals affirmed in part and reversed in part, finding that the claim based on excessive speed was preempted, but the warning device claim was not. Id. The Supreme Court affirmed the Court of Appeals' decision.