Medtronic, Inc. v. Lohr (Medtronic)

In Medtronic, Inc. v. Lohr (Medtronic) (1996) 518 U.S. 470, the United States Supreme Court specified the proper approach in analyzing a statute that includes explicit preemption language. Although an express preemption provision may indicate congressional intent to preempt "at least some state law," a court must nevertheless " 'identify the domain expressly pre-empted' by that language." ( Id. at p. 484 116 S. Ct. at p. 2250.) Two presumptions guide the process of determining the scope of an express preemption provision. First, as in answering the threshold question of whether Congress intended preemption to occur, the assumption that preemption will not lie absent evidence of a clear and manifest congressional purpose must also be applied in measuring the "scope of Congress's intended invalidation of state law." ( Medtronic, supra, 518 U.S. at p. 485.) Second, while Congress's intent "primarily is discerned from the language of the pre-emption statute and the 'statutory framework' surrounding it, also relevant . . . is the 'structure and purpose of the statute as a whole,' . . . as revealed not only in the text, but through the reviewing court's reasoned understanding of the way in which Congress intended the statute and its surrounding regulatory scheme to affect business, consumers, and the law." ( Id. at pp. 485-486.)