Association of American Railroads v. Seggos
- Ronnie Abrams
- 1:24-cv-00135
- U.S. District Court · Southern District of New York
- 2
In Association of American Railroads v. Seggos, Judge Abrams ordered parties to address factual issues relevant to a railroad-safety preemption motion.
The plaintiffs and the New York officials sued as defendants were required to submit letters addressing the factual issues relevant to the motion to dismiss.
What happened
Association of American Railroads v. Seggos concerns whether New York’s Waste By Rail Law relates to railroad safety and may be displaced by federal law. The parties agreed that discovery was unnecessary, but they made conflicting factual assertions about the law’s safety effects.
The court explained that deciding federal preemption can sometimes require resolving underlying factual disputes. It ordered each side to file a letter by March 10, 2025, addressing whether such disputes are necessary and whether the court should treat the complaint’s factual allegations as true for the motion to dismiss.
Judge Abrams did not decide the preemption question or the motion to dismiss in this order. The order instead required the parties to provide their positions on how the factual issues should be handled.
The detailed version
- Association of American Railroads v. Seggos · No. 1:24-cv-00135
- Ronnie Abrams
- Mar. 3, 2025
Background
The plaintiffs are the Association of American Railroads, the American Short Line and Regional Railroad Association, and the National Waste & Recycling Association – New York State Chapter. The defendants are Basil Seggos, Commissioner of the New York Department of Environmental Conservation, and Letitia James, Attorney General of New York, sued in their official capacities.
The dispute concerns whether the Waste By Rail Law is related to railroad safety under 49 U.S.C. § 20106(a), a federal railroad-safety provision that can be relevant to whether federal law preempts, or displaces, state law. The plaintiffs alleged that coverings required by the Waste By Rail Law are unnecessary to protect public health and safety. The defendants argued that solid waste could spill from a rail car without a sealed hard lid or if it were piled too high, potentially causing injuries from railroad-related accidents and incidents.
Court’s Analysis
At oral argument, both sides agreed that discovery was unnecessary to determine whether the Waste By Rail Law relates to railroad safety. The court nevertheless noted that the parties appeared to make competing factual assertions on that issue.
The court explained that a preemption determination can sometimes require resolving “subsidiary factual disputes” that are part of the broader legal question. It also noted that courts in earlier railroad-preemption cases appeared to rely on factual records when deciding whether state or local measures related to railroad safety. The court further cited authority stating that, on a motion to dismiss, factual allegations relevant to preemption generally must be viewed in the light most favorable to the plaintiff.
Order and Effect
The court ordered each party to file a letter no later than March 10, 2025, stating its position on two issues: whether deciding the Waste By Rail Law’s effect on railroad safety requires resolving subsidiary factual disputes, and whether the court should assume the complaint’s factual allegations are true for purposes of the motion to dismiss.
This order did not grant or deny the motion to dismiss and did not decide whether federal law preempts the Waste By Rail Law. Judge Ronnie Abrams issued the order on March 3, 2025.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.