Gade v. National Solid Wastes Management Association

Illinois imposed training, examination, experience, and licensing requirements on hazardous-waste facility employees and equipment operators, and the National Solid Wastes Management Association (plaintiff) challenged the requirements as preempted by OSHA and as violating the Commerce Clause; the district court found no preemption because the state law also served public-safety goals beyond OSHA's workplace-safety purpose, though it struck a provision requiring in-state training, and the court of appeals affirmed in part and reversed in part before Illinois (defendant) sought Supreme Court review.