In Walker v. St. Louis-Southwestern Railway,' the Missouri Court of Appeals, Eastern District, faced the issue of whether the Federal Railroad Safety Act (FRSA)2 pre-empted state tort law. This was an issue of first impression in the Eastern District of Missouri The FRSA was enacted in 1970, but courts have only recently started considering its pre-emptive effect.
John Woodson Rogers,
Federal Pre-Emption of State Railroad Tort Law: The Misuse of the Federal Railroad Safety Act to Insulate Railroads from Liability,
58 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol58/iss2/3