State of Ohio v. CSX Transportation, Inc.

Summary

The Supreme Court of Ohio held that Ohio’s railroad antiblocking statute, R.C. 5589.21, is expressly preempted by the Interstate Commerce Commission Termination Act because it regulates the operation and movement of trains. The court further held that the Federal Railroad Safety Act does not exempt the statute from preemption because the law addresses public-safety concerns at crossings rather than the safe operation of railroads. The court reversed the Third District Court of Appeals and reinstated the trial court’s dismissal of all charges against CSX Transportation, Inc.

Holdings

1. The Ohio antiblocking statute is expressly preempted by the Interstate Commerce Commission Termination Act because it regulates the operation and movement of railroad equipment and provides state remedies concerning rail transportation that Congress committed exclusively to the Surface Transportation Board.
2. The Federal Railroad Safety Act does not exempt section 5589.21 from the Termination Act's preemptive force because the Ohio statute concerns public-safety consequences of blocked crossings rather than the safe operation of railroad trains, and it does not qualify for the Federal Railroad Safety Act's local-safety savings clause.

Questions Presented

1. Whether Ohio Revised Code section 5589.21 is expressly preempted by the Interstate Commerce Commission Termination Act.
2. Whether Ohio Revised Code section 5589.21 is preempted by, or falls within a savings clause of, the Federal Railroad Safety Act.

Disposition

reversed