People v. Transamerican Freight Lines, Inc., 24 N.Y.2d 727 (1969)
When state and federal regulations share the same purpose and are harmonious, the state retains jurisdiction even if the United States has acted in the same area.
Summary
Transamerican Freight Lines was convicted under a New York statute for failing to mark a truck carrying a dangerous article. The truck contained ethylene oxide, a flammable liquid. The defendants argued that federal law preempted the state statute. The Court of Appeals upheld the conviction, finding that the state and federal regulations were harmonious and shared the same objectives of safety. The court reasoned that the state statute was not invalidated because the federal government also regulated the interstate shipment of dangerous materials.
Facts
On September 8, 1966, a Transamerican Freight Lines truck was stopped at the Holland Tunnel. The bill of lading indicated the truck carried 15 drums of ethylene oxide. The drums had red labels with safety directions and tags stating “Ethylene Oxide, 99% pure” and “Danger: Extremely flammable.” No warning of the cargo’s contents appeared on the outside of the truck. Ethylene oxide has a flash point of minus four degrees Fahrenheit.
Procedural History
The defendants were prosecuted under Section 380 of the New York Vehicle and Traffic Law for failing to mark the truck as carrying a dangerous article. The trial court convicted the defendants. The defendants appealed, arguing federal preemption. The New York Court of Appeals affirmed the conviction.
Issue(s)
1. Whether the prosecution established a prima facie case that the truck was carrying a dangerous article as defined by the New York statute.
2. Whether federal law preempts subdivision 3 of Section 380 of the New York Vehicle and Traffic Law regarding the regulation of interstate shipment of dangerous materials.
Holding
1. Yes, because the bill of lading, the markings on the drums, and the expert testimony established that the truck was carrying ethylene oxide, a dangerous article under the statute.
2. No, because the state and federal laws are harmonious and share the same objective of safety, and thus the state statute is not preempted.
Court’s Reasoning
The court found that the prosecution presented a prima facie case based on circumstantial evidence. The bill of lading, drum markings, and expert testimony established that the truck carried ethylene oxide, a dangerous article as defined by the state statute. The court then addressed the preemption argument, noting that both federal and state laws aimed to regulate dangerous substances in transit. The court emphasized that specifics were left to the regulations of the Interstate Commerce Commission, which closely mirrored the New York statute. The court distinguished this case from cases like Castle v. Hayes Frgt. Lines, where state regulations directly interfered with federally authorized activities. Here, the court stated:
“When State and Federal regulatory statutes have the same purpose and are harmonious, as the statutes regulating dangerous substances in transit certainly are, the State is not ousted of jurisdiction because the United States has also acted (California v. Zook, 336 U. S. 725).”
The court further explained that state and federal regulations in such situations could “have their separate spheres of operation” (Union Brokerage Co. v. Jensen, 322 U. S. 202, 208). The state’s regulation was a valid exercise of its power to provide for safety on its highways, consistent with federal interstate regulations.