Association of American Railroads v. Seggos
- Ronnie Abrams
- 1:24-cv-00135
- U.S. District Court · Southern District of New York
- 4
In Association of American Railroads v. Seggos, Judge Abrams adjourned the plan and proposed scheduling order while defendants’ dismissal motion remained pending.
The three plaintiff trade associations, their members involved in solid-waste rail shipments, and the New York officials responsible for enforcing the Waste By Rail Law are affected by the delayed case scheduling. The order itself does not decide the law’s validity or the pending dismissal motion.
What happened
Association of American Railroads v. Seggos concerns a challenge by three trade associations to New York’s Waste By Rail Law, which requires covered solid waste to be covered during rail transportation within New York. The associations seek to block enforcement, arguing that federal law overrides the state law.
The defendants argue that the state law is a railroad-safety regulation and that the complaint should be dismissed for failing to state a claim. Their motion to dismiss was pending, and the parties proposed waiting for the court’s decision before beginning discovery and setting the case schedule.
Judge Ronnie Abrams adjourned the plan and proposed scheduling order. The text does not decide the pending motion to dismiss, the federal-preemption claims, or whether discovery will occur.
The detailed version
- Association of American Railroads v. Seggos · No. 1:24-cv-00135
- Ronnie Abrams
- Apr. 2, 2024
Background
Three trade associations whose members are involved in shipping solid waste by rail sued to stop enforcement of New York’s Waste By Rail Law. The law amended New York’s Environmental Conservation Law and, for the first time, required rail cars carrying solid waste to have covers when operating within New York.
The plaintiffs contend that the law disrupts interstate rail networks and is preempted, meaning overridden, by federal law. They primarily invoke the Interstate Commerce Commission Termination Act, which they say preempts state laws governing, burdening, or discriminating against rail transportation. They also argue that the law would be preempted by the Federal Railroad Safety Act and the Hazardous Materials Transportation Act if it were treated as a safety regulation.
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. They argue that the case concerns railroad safety rather than economic regulation and that the complaint fails to state a claim because the Interstate Commerce Commission Termination Act does not apply. They also contend that the state law is not preempted under the Federal Railroad Safety Act because no federal regulation or order covers the same subject.
Pending Motion and Proposed Schedule
The defendants filed a motion to dismiss for failure to state a claim on March 6, 2024. The plaintiffs’ opposition and the defendants’ reply were scheduled for later filing. No discovery had occurred.
The parties jointly proposed deferring discovery, initial disclosures, a full case-management plan, and further scheduling until after the court ruled on the motion to dismiss. They also proposed postponing the initial status conference. The plaintiffs stated that the issues were legal and that summary judgment motions might be appropriate if the dismissal motion did not resolve the case. The defendants stated that, if their motion were denied, the parties could then determine whether discovery was needed.
Court’s Action
Judge Ronnie Abrams ordered that the plan and proposed scheduling order be adjourned. The provided text does not state that the court granted or denied the motion to dismiss, rule on preemption, postpone the initial status conference, or otherwise decide the merits of the lawsuit.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.