People v. Chicago Wire Magnet Corp.

The people of the State of Illinois (state) (plaintiff) indicted Chicago Wire Magnet Corporation (company) (defendant) for aggravated battery and related offenses. The indictments charged that the company knowingly and recklessly injured 42 employees by failing to take necessary safety precautions to avoid exposure to toxic substances used by the company in its manufacturing processes. Federal standards issued by the Occupational Safety and Health Administration (OSHA) identified permissible exposure limits for the toxic substances at issue and regulated the company’s activities that were alleged to be unsafe. The company moved to dismiss the indictments on the grounds that they were preempted by the Occupational Safety and Health Act (act). Under § 18 of the act, a state could assume responsibility for developing and enforcing occupational safety and health standards relating to any matter for which federal standards had been issued by submitting a plan for development and enforcement of state standards. In addition, § 2 of the act provided that states were to assume responsibility for the administration and enforcement of their occupational safety and health laws. Because Illinois had not received approval from OSHA to develop and enforce its own standards, the company reasoned that the state did not have the authority to prosecute the alleged violations. The trial court granted the company’s motion to dismiss. The court of appeals affirmed, and the state appealed.