Association of American Railroads et al. v. Lefton
- Ronnie Abrams
- 1:24-cv-00135
- U.S. District Court · Southern District of New York
- 3
In Ass’n of American Railroads v. Lefton, Judge Figueredo ordered plaintiffs to respond to a discovery motion and extended fact discovery to November 28, 2025.
The plaintiffs, particularly the Association of American Railroads, must respond to the discovery motion by October 9, 2025. The extended fact-discovery deadline affects the parties in the case.
What happened
Ass’n of American Railroads et al. v. Lefton et al. concerns a challenge to New York’s 2023 “Waste by Rail” Law, which sets requirements for covering waste transported by rail. The defendants’ state-lawyer asked the court to require the Association of American Railroads to provide nationwide information about waste and construction debris falling from open-top rail cars.
The state argued that this information could help show that the law relates to railroad safety and therefore is not barred by federal railroad-safety law. The Association objected that the requests were too broad because they covered incidents outside New York.
Judge Valerie Figueredo directed the plaintiffs to respond by October 9, 2025, and extended the fact-discovery deadline to November 28, 2025. The text does not state that the court granted or denied the request to compel documents.
The detailed version
- Association of American Railroads et al. v. Lefton · No. 1:24-cv-00135
- Ronnie Abrams
- Oct. 2, 2025
Background
The plaintiffs challenge New York’s 2023 “Waste by Rail” Law as preempted, meaning they contend federal law displaces or prevents enforcement of the state law. The law sets requirements for covering waste transported by rail within New York. The New York State Office of the Attorney General represents the defendants.
Discovery dispute
The state asked for a discovery conference and an order compelling plaintiff Association of American Railroads (AAR) to respond to two document requests served on June 27, 2025. Request No. 8 sought documents about municipal solid waste falling from open-top rail cars in the United States. Request No. 10 sought similar documents concerning construction and demolition debris. AAR objected to the requests’ nationwide scope and argued that they should be limited to incidents in New York.
The state argued that the requested information was relevant and proportional under Federal Rule of Civil Procedure 26. It relied on a federal railroad-safety statute’s savings provision, which can allow a state to maintain a railroad-safety law until the federal government issues a regulation or order covering the same subject. The state also cited an earlier order in this case stating that discovery about whether the Waste by Rail Law implicates railway safety could affect the preemption analysis.
The letter described several New York incidents involving cargo or debris striking trains, falling from trains, or causing damage. It also referred to more than 30 publicly available federal summaries of nationwide rail incidents involving loads falling from rail cars. The state argued that the federal summaries were incomplete and that the railroads had more detailed information.
Court action
The order directs the plaintiffs to file a response by October 9, 2025. It also extends the deadline for completing fact discovery to November 28, 2025. The provided text does not state that Judge Valerie Figueredo ruled on whether AAR must produce the requested documents, and it does not state a ruling on the underlying preemption challenge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.