ST. LOUIS — A federal judge in the Eastern District of Missouri has dismissed several claims in a lawsuit stemming from a 2015 train-vehicle collision while ordering the remaining claims to be remanded to state court, concluding that federal law preempts key portions of the plaintiff’s allegations and leaves no basis for federal jurisdiction.
In an opinion, memorandum and order issued March 26, U.S. District Judge Henry Edward Autrey granted the defendant railroad company’s partial motion to dismiss and also granted the plaintiff’s motion to remand the case to Missouri state court.
The case involves claims brought by Gregory Lawson against The Kansas City Southern Railway Company following a collision between a train and Lawson’s vehicle on June 29, 2015, in Hillview, Illinois.
According to the complaint, Lawson alleged that he was crossing railroad tracks on County Road 460 East when his vehicle was struck by a train owned and operated by the defendant.
He asserted multiple negligence claims, including allegations that the railroad failed to sound a whistle, maintain a proper lookout, control vegetation near the tracks, inspect and maintain equipment and provide adequate warnings at the crossing.
The defendant removed the case from state court to federal court, arguing that Lawson’s claims raised federal questions because they referenced compliance with regulations issued by the Federal Railroad Administration.
However, the court ultimately determined that while some claims implicated federal law, those claims were preempted and therefore could not proceed.
Autrey found that several of Lawson’s negligence claims were preempted by the Federal Railroad Safety Act (FRSA) and the Locomotive Inspection Act (LIA), which govern railroad safety and equipment standards at the federal level.
Specifically, the court ruled that claims related to the failure to sound a train horn are preempted because federal regulations establish uniform requirements for horn use at public highway-rail grade crossings.
The court also dismissed claims alleging that the railroad failed to maintain a proper lookout and to inspect the tracks, concluding that those issues are covered by federal regulations that govern inspection standards and responsibilities.
Similarly, allegations involving vegetation control along the tracks were found to be preempted because federal rules address the management of vegetation on or near railroad property.
Additionally, the court held that claims regarding the inspection and maintenance of the train’s engines fall under the exclusive authority of the Locomotive Inspection Act, which preempts state law in that area.
The defendant also sought dismissal of certain state-law negligence claims under an Illinois statute, arguing that it does not create a private right of action.
The court addressed these arguments within its broader analysis of the claims’ legal sufficiency and preemption.
After dismissing the federally preempted claims, the court turned to the question of jurisdiction. Although the case had been properly removed based on the presence of federal issues, the dismissal of those claims meant that no federal question remained.
Without any surviving claims arising under federal law, the court determined it no longer had original jurisdiction and declined to retain supplemental jurisdiction over the remaining state law claims.
As a result, Autrey granted Lawson’s motion to remand, sending the case back to the Circuit Court for the County of St. Louis, Missouri.
The order concludes that both the defendant’s motion to dismiss and the plaintiff’s motion to remand are granted, effectively narrowing the scope of the lawsuit and returning it to state court for further proceedings on any remaining claims not barred by federal law.
U.S. District Court for the Eastern District of Missouri, Eastern Division case number: 4:25-cv-661
