In Delaware & Hudson Railway Co. v. Knoedler Manufacturers, Inc., No. 13-3678 (3d Cir. Jan. 9, 2015), the Third Circuit addressed the question of the scope of federal preemption under the Locomotive Inspection Act (“LIA”).  The plaintiff railroad, which previously had settled a lawsuit brought against it by employees who had suffered injuries as a result of allegedly defective train seats, sued the companies that had manufactured and repaired the chairs.  The defendants moved for and obtained dismissal of this lawsuit based on the preemptive effect of the LIA.  The Third Circuit ruled that, while the LIA preempts state law standards being imposed upon locomotives and their component parts, it does not preempt state law actions based on allegations that locomotive components violate federal standards.  Consequently, the court reversed the dismissal of the case below and remanded for further proceedings on plaintiff’s claims that defendants had violated federal standards.