People v. Chicago Magnet Wire Corp

In People v. Chicago Magnet Wire Corp., 126 Ill. 2d 356, 534 N.E.2d 962, 965, 128 Ill. Dec. 517 (Ill. 1989), corporate officers were charged with several criminal offenses after numerous employees suffered physical injuries due to their exposure to toxic substances, inadequate ventilation and dangerously overheated working conditions. The indictments claimed the defendants knowingly and recklessly caused the injuries by failing to provide the employees with necessary safety precautions to avoid harmful exposure to the poisonous substances. The defendants argued that OSHA preempted the prosecutions on several grounds. The Supreme Court of Illinois disagreed and reversed the appellate court, which had affirmed an order dismissing the indictments. Id. at 963-64. The Illinois Supreme Court discussed the doctrine of federal preemption under the Supremacy Clause of the United States Constitution and analyzed the language, history and purpose of OSHA. The court held that, "there is nothing in the structure of OSHA or its legislative history which indicates that Congress intended to preempt the enforcement of State criminal law prohibiting conduct of employers that is also governed by OSHA safety standards." Id. at 966. The court stated that: "We cannot see that State prosecution of employers for conduct which is regulated by OSHA would conflict with the administration of OSHA regulations or be at odds with its goals or purposes. On the contrary, prosecution of employers who violate State criminal law by failing to maintain safe working conditions for their employees will surely further OSHA's stated goal of "assuring so far as possible every working man and woman in the Nation safe and healthful working conditions." (29 U.S.C.A. 651(b)(1982). State criminal law can provide valuable and forceful supplement to insure that workers are more adequately protected and that particularly egregious conduct receives appropriate punishment." Id. at 969.