In the case of CSX Transportation, Inc. v. Lizzie Beatrice Easterwood (1992), the U.S. Supreme Court ruled that federal law preempts state negligence claims concerning train speed in railway accidents but does not preempt claims related to inadequate maintenance or failure to warn at a railroad crossing. The lawsuit was initiated by Lizzie Beatrice Easterwood after her husband died in a collision with a CSX train at an unguarded Georgia crossing where no warning signals were installed apart from standard crossbuck signs. She claimed that CSX had been negligent because it failed to maintain safe speeds and did not provide adequate warnings about the dangers of the crossing site. The court held that while Federal Railroad Safety Act regulations regarding maximum allowable speeds supersede any relevant state laws, they do not cover other aspects such as track maintenance or safety measures at crossings, leaving room for states' tort actions on these matters.

In the dissenting opinion for CSX Transportation, Inc. v. Lizzie Beatrice Easterwood, Justice Thomas argued that federal law does not preempt state negligence claims related to train speed in railroad accidents. He contended that the Federal Railroad Safety Act (FRSA) was designed to establish minimum safety standards and did not intend to prevent states from imposing stricter requirements or pursuing additional remedies under common law. The majority's interpretation of FRSA as setting a maximum allowable speed limit effectively nullifies any potential state regulation or litigation concerning excessive train speeds, which he believed contradicts Congress' intent when passing the legislation. Furthermore, he disagreed with the majority's reliance on an administrative agency’s regulations rather than statutory text in determining preemption.