Medtronic v. Lohr
In Medtronic, Inc. v. Lohr, 518 U.S. 470 (1996), the U.S. Supreme Court held, in a products liability case, that federal law does not preempt common law causes of action for recovery of damages. "At this early stage in the litigation, there was no reason for the Court of Appeals to preclude altogether the Lohrs' manufacturing and labeling claims to the extent that they rest on claims that Medtronic negligently failed to comply with duties 'equal to, or substantially identical to, requirements imposed' under federal law." Id. at 496-97.
The Court, in a splintered decision written by Justice John Paul Stevens, emphasized that:
- First, because the States are independent sovereigns in our federal system, we have long presumed that Congress does not cavalierly pre-empt state-law causes of action. In all pre-emption cases, and particularly in those in which Congress has "legislated ... in a field which the States have traditionally occupied," Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230, 91 L. Ed. 1447, 67 S. Ct. 1146 (1947), we "start with the assumption that the historic police powers of the States were not to be superseded by the Federal Act unless that was the clear and manifest purpose of Congress." Ibid.; Hillsborough Cty., 471 U.S. at 715-716; cf. Fort Halifax Packing Co. v. Coyne, 482 U.S. 1, 22, 96 L. Ed. 2d 1, 107 S. Ct. 2211 (1987). Although dissenting Justices have argued that this assumption should apply only to the question whether Congress intended any pre-emption at all, as opposed to questions concerning the scope of its intended invalidation of state law, see Cipollone, 505 U.S. at 545-546 (SCALIA, J., concurring in judgment in part and dissenting in part), we used a "presumption against the pre-emption of state police power regulations" to support a narrow interpretation of such an express command in Cipollone. Id., at 518, 523. That approach is consistent with both federalism concerns and the historic primacy of state regulation of matters of health and safety."
Id. at 485.