Napier v. Atlantic Coast Line Railroad Co

In Napier v. Atlantic Coast Line Railroad Co., 272 U.S. 605, 607, 47 S. Ct. 207, 71 L. Ed. 432 (1926) the Court considered challenges to a Georgia statute requiring that locomotive fireboxes be equipped with an automatic door, and to a Wisconsin statute requiring locomotives to have cab curtains. The Court found that LIA was "intended to occupy the field" pertaining to "the design, the construction, and the material of every part of the locomotive and tender and of all appurtenances." Id. at 611, 613. Under LIA, only the federal agency tasked with implementing LIA could "set the standard" for a locomotive's proper operating condition, and any "requirements by the states are precluded, however commendable or however different their purpose." Id. at 612-13.