Napier v. Atlantic Coast Line Railroad Co.
1926 United States Supreme Court case
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Napier v. Atlantic Coast Line Railroad Co., 272 U.S. 605 (1926), was a United States Supreme Court case in which the court held that the Boiler Inspection Act has so occupied the field of regulating locomotive equipment on interstate highways that state legislation requiring cab curtains and automatic firebox doors is precluded and must be addressed by the Interstate Commerce Commission.[1][2][3]
Full case nameNapier v. Atlantic Coast Line Railroad Co.
MajorityBrandeis, joined by unanimous
| Napier v. Atlantic Coast Line Railroad Co. | |
|---|---|
 | |
| Decided November 29, 1926 | |
| Full case name | Napier v. Atlantic Coast Line Railroad Co. |
| Citations | 272 U.S. 605 (more) |
| Holding | |
| The Boiler Inspection Act has so occupied the field of regulating locomotive equipment on interstate highways that state legislation requiring cab curtains and automatic firebox doors is precluded and must be addressed by the Interstate Commerce Commission. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Brandeis, joined by unanimous |
| Laws applied | |
| Boiler Inspection Act | |
Later developments
The Supreme Court returned to the Boiler Inspection Act, now renamed the Locomotive Inspection Act, in Kurns v. Railroad Friction Products Corp., a case in which the court also held that field preemption applied.[3]
