United Air Lines, Inc. v. Division of Industrial Safety of the Department of Industrial Relations
Headline: Court refused to review the appeals court’s dismissal, leaving California inspections of United Airlines’ maintenance facilities subject to state enforcement while FAA preemption questions remain unresolved.
Holding:
- Leaves state safety inspections enforceable against airline maintenance facilities for now.
- Creates uncertainty over whether FAA oversight blocks state enforcement of workplace rules.
- Raises the prospect that companies may need federal courts to resolve preemption disputes.
Summary
Background
United Airlines operates maintenance facilities at San Francisco International Airport. California’s Division of Occupational Safety and Health (Cal/OSH) inspected those facilities between June 1976 and August 1978 and issued citations for alleged health and safety violations. United argued that federal FAA supervision preempts state enforcement, sued in federal court, and sought an order and injunction to stop further state inspections and proceedings.
Reasoning
The central question was whether federal courts should decide United’s claim that the Federal Aviation Administration (FAA) has exclusive authority over aircraft maintenance safety, which would bar state enforcement. The District Court granted a preliminary injunction for United, but the Ninth Circuit reversed and dismissed the federal suit as beyond federal court power. The Supreme Court refused to review that dismissal, leaving the appeals court’s decision intact.
Real world impact
As a practical matter, the lower courts’ view controls for now: United’s federal challenge was dismissed and state inspections and citations proceed through state channels. United had also tried to block proceedings before the state Occupational Safety and Health Appeals Board, so the outcome affects both inspections and state administrative enforcement. The question whether FAA oversight preempts state workplace safety enforcement remains open and unresolved by the Supreme Court.
Dissents or concurrances
Justice White dissented from the denial of review, arguing the case raised an important national question about federal preemption and federal-court power and urging the Court to hear the issue, noting prior cases where preemption claims reached federal court.
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