In 2014, the California legislature passed the Healthy Workplaces, Healthy Families Act, which requires employers to provide a minimum of 24 hours “paid sick leave” or three “paid sick days” per year to every employee working in California.

Six railroad companies brought suit against the California Labor Commissioner. The railroads alleged that the California Act was invalid as applied to their employees.

The 9th Circuit agreed with the railroad companies. National Railroad Passenger Corporation v. Brotherhood of Locomotive Engineers And Trainmen (9th Cir 07/26/2022). [PDF]

The federal Railroad Unemployment Insurance Act (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 court concluded that the preemption provision broadly refers to compensation or other assistance provided to employees in connection with physical or mental well-being. The court concluded that RUIA’s statutory framework and stated purposes confirm the breadth of its preemptive effect.

The court said: "Properly considered in light of RUIA’s plain text and structure, the California Act is a 'sickness law' that provides 'sickness benefits.'"