In Kurns v. R.R. Friction Prods. Corp., U.S. 132 S. Ct. 1261, 1268-69, 182 L. Ed. 2d 116 (2012), the Court rejected as preempted state common-law design defect and failure-to-warn claims against the manufacturer of locomotive equipment containing asbestos. 132 S. Ct. at 1264, 1269-70. Although the claims in Kurns were based on state common-law duties rather than on state legislation, the Court concluded that "state common-law duties and standards of care directed to the subject of locomotive equipment are pre-empted by LIA." Id. at 1269-70.