See: Supreme Court Rules State Tort Law Claims Preempted by Federal Locomotive Statute (Justica.com)
"Justice Elena Kagan, in her concurring opinion, concluded that the design-defect and failure-to-warn claims were preempted by the LIA because "Napier recognized the federal agency's delegated authority over "the design, the construction and the material of every part of the locomotive."" Justice Sonia Sotomayor concurred in part and dissented in part, and was joined by Justices Stephen Breyer and Ruth Bader Ginsburg. Though they agreed that the design-defect claim was preempted by the LIA, they concluded that the failure-to-warn claim was not preempted because the field defined in Napier differently today because recent cases have regularly rejected the field preemption doctrine when statutory language does not contain an express preemption clause."
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