Issue: Under federal law as applied in California, what principles should guide a court in determining whether Congress intended FIFA (Federal Insecticide Fungicide and Rodenticide Act) to preempt all state-law claims against a manufacturer subject to its regulations?
| Area of Law: | Litigation & Procedure, Personal Injury & Negligence |
| Keywords: | Preemption of state law; Manufacturer's liability; FIFRA (Federal Insecticide Fungicide and Rodenticide Act) |
| Jurisdiction: | California |
| Cited Cases: | 505 U.S. 504 |
| Cited Statutes: | U.S. Const. Article VI, cl. 2; |
| Date: | 01/01/2001 |
Preemption of state law under FIFRA is narrow and limited to claims alleging a failure-to-warn theory derived from an inadequate label. Preemption under FIFRA does not apply to design-defect claims that are supported by evidence that alternative, safer formulations of the particular product exist. Where a plaintiffs’ claims for strict liability and negligence are based upon defective design that would require the defendant to change its product rather than the label, they are not preempted.
The doctrine of federal preemption is based on the Supremacy Clause. U.S. Const. Article VI, cl. 2; Cipollone v. Liggett Group, Inc. (1992) 505 U.S. 504, 516. Under this doctrine, any state law that conflicts with federal law has no effect. Cipollone, 505 U.S. at 516. When interpreting a statutory provision such as FIFRA’s express preemption provision, the reviewing court’s responsibility is to "’identify the domain expressly preempted’" by the language of the statute. Medtronic, Inc. v. Lohr (1996) 116 S. Ct. 2240, 2250 (quoting Cippollone, 505 U.S. at 517). Two important presumptions must guide the reviewing court’s task of statutory interpretation. Id. at 2250. First, a presumption against preemption of common-law claims such as those at issue here has long been the rule, given the role of the states as independent sovereigns in our federal system of government. Id. (citing cases). Second, only if Congress clearly and manifestly expresses its intent to preempt state law can this presumption be overcome. Congressional purpose or intent to preempt claims based on state law may […]