Coalition of railroads wins ruling rejecting Massachusetts law on paid sick leave

Client(s) CSX Transportation, Inc., CSX Intermodal Terminals, Inc., National Railroad Passenger Corporation (d/b/a Amtrak), and Springfield Terminal Railway Company

On July 13, 2016, a federal district court in Massachusetts issued a ruling in favor of our clients, a coalition of railroads, holding that the new Massachusetts "Earned Sick Time" statute is preempted by federal law. The railroads had brought suit in 2015, arguing that the Massachusetts state law -- which requires all employers in the state to provide paid sick leave to their employees -- was preempted by the Railroad Unemployment Insurance Act ("RUIA"). The RUIA contains an express preemption clause, providing that it shall be the "exclusive" source of "sickness benefits" for railroad employees. The Commonwealth -- supported by both a coalition of labor union intervenors and the United States -- argued that the RUIA preempts only state-mandated "short term disability plans," and not paid sick leave. In the Court's ruling on the parties' cross-motions for partial summary judgment, the Court rejected the Commonwealth's argument and agreed with the railroads that under the RUIA, "all state sickness laws, without qualification, would unduly burden and interfere with federal regulation and should thus be preempted."

The Massachusetts court's ruling is the first to interpret the scope of RUIA preemption. It is significant because a number of other states and localities have passed or are in the process of passing paid sick leave legislation, and the railroads have raised or will be raising preemption arguments in each such case.

CSX Transportation v. Attorney General of the Commonwealth of Massachusetts, No. 1:15-cv-12865 (D. Mass.)