NAT'L RAILROAD PASSENGER CORP. V. JULIE SU, No. 21-15816 (9th Cir. 2022)

Court Description: Railroad Unemployment Insurance Act / Preemption Affirming the district court’s summary judgment in favor of National Railroad Passenger Corporation and other railroad companies, the panel held that, as to railroad employees, the federal Railroad Unemployment Insurance Act preempts California’s Healthy Workplaces, Healthy Families Act, which requires employers to provide employees with paid sick leave that they may use for specified purposes. RUIA provides unemployment and sickness benefits to railroad employees, and it contains an express preemption provision disallowing railroad employees from having any right to “sickness benefits under a sickness law of any State.” Looking to the plain meaning of the statutory text, the panel concluded that the preemption provision broadly refers to compensation or other assistance provided to employees in connection with physical or mental well-being. The panel concluded that RUIA’s statutory framework and stated purposes confirm the breadth of its preemptive effect. The panel held that, as applied to railroad employees, the California Act falls within RUIA’s preemption clause because, properly considered in light of RUIA’s plain text and structure, the California Act is a “sickness law” that provides “sickness benefits.” 4 NRPC V. BLET Agreeing with the First Circuit, the panel found unpersuasive an argument by the California Labor Commissioner and union-intervenors that RUIA does not preempt the California Act as to railroad employees because the benefits the Act offers are different in kind than RUIA’s benefits. The panel also found unpersuasive (1) an argument that RUIA should be interpreted as preempting only the kinds of state laws that existed at the time RUIA was amended to provide for sickness benefits; and (2) various textual arguments in support of a narrower interpretation of the preemption provision.