Napier v. Atlantic Coast Line Railroad Co.

Napier v. Atlantic Coast Line Railroad Co.
Decided November 29, 1926
Full case nameNapier v. Atlantic Coast Line Railroad Co.
Citations272 U.S. 605 (more)
Holding
The Boiler Inspection Act has so occupied the field of regulating locomotive equipment on interstate highways that state legislation requiring cab curtains and automatic firebox doors is precluded and must be addressed by the Interstate Commerce Commission.
Court membership
Chief Justice
William H. Taft
Associate Justices
Oliver W. Holmes Jr. · Willis Van Devanter
James C. McReynolds · Louis Brandeis
George Sutherland · Pierce Butler
Edward T. Sanford · Harlan F. Stone
Case opinion
MajorityBrandeis, joined by unanimous
Laws applied
Boiler Inspection Act

Napier v. Atlantic Coast Line Railroad Co., 272 U.S. 605 (1926), was a United States Supreme Court case in which the court held that the Boiler Inspection Act has so occupied the field of regulating locomotive equipment on interstate highways that state legislation requiring cab curtains and automatic firebox doors is precluded and must be addressed by the Interstate Commerce Commission.[1][2][3]

Later developments

The Supreme Court returned to the Boiler Inspection Act, now renamed the Locomotive Inspection Act, in Kurns v. Railroad Friction Products Corp., a case in which the court also held that field preemption applied.[3]

References

  1. ^ Napier v. Atlantic Coast Line Railroad Co., 272 U.S. 605 (1926).
  2. ^ Stein, A. L. (1937). "State and Federal Regulation of Railroad Safety Devices". The Journal of Land & Public Utility Economics. 13 (4): 427–429. doi:10.2307/3158234. ISSN 1548-9000.
  3. ^ a b Rebecca Diel, "Derailed: The Locomotive Inspection Act and the Need to Extend the Field Preemption", 45 McGeorge L. Rev. 739 (2014).
  • Text of Napier v. Atlantic Coast Line Railroad Co., 272 U.S. 605 (1926) is available from: Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain.