## Facts

- Chicago Magnet Wire Corporation operated a wire-coating facility where manufacturing involved toxic, federally regulated substances.
- The State alleged that the corporation and five corporate officials exposed employees to hazardous substances and unsafe conditions.
- Alleged failures included inadequate safety instructions and equipment, insufficient health monitoring, inadequate ventilation, and dangerously overheated working conditions.
- The State alleged that numerous employees suffered serious physical injuries from these workplace conditions.
- Federal workplace-safety authorities had inspected the facility and resolved certain regulatory matters through an administrative settlement before the state criminal case proceeded.

## Issues

1. Whether the federal Occupational Safety and Health Act of 1970 (OSHA) preempts Illinois from prosecuting an employer and corporate officers under generally applicable state criminal statutes for workplace conduct regulated by OSHA standards, absent an approved state plan.

## Decision

- The Illinois Supreme Court reversed the dismissal of the indictments and remanded for further proceedings.
- The court held that OSHA does not preempt state criminal prosecutions under general criminal laws (including aggravated battery, reckless conduct, and conspiracy) based on workplace conduct that also falls within OSHA’s regulatory scope.
- The court rejected the view that applying general criminal statutes in this context amounts to enforcing state occupational safety “standards” requiring federal approval.

## Legal Principles

- Preemption of traditional state police powers, including criminal law, is not inferred absent a clear congressional intent.
- OSHA’s statutory text, including its savings clause preserving state-law rights, duties, and liabilities, indicates Congress did not displace generally applicable state remedies merely because conduct occurs in a regulated workplace.
- OSHA preemption under the state-plan provision concerns state occupational safety and health “standards,” not generally applicable criminal prohibitions that protect persons from physical injury.
- Prior federal administrative enforcement or settlement under OSHA does not immunize defendants from independent state criminal liability for conduct satisfying the elements of state crimes.

## Conclusion

Illinois may prosecute an employer and corporate officials under generally applicable criminal laws for workplace conduct causing injury, even when the same conditions are subject to OSHA regulation, because OSHA does not preempt such state criminal proceedings.


People v. Chicago Magnet Wire Corp., 126 Ill. 2d 356, 534 N.E.2d 962 (Ill. 1989)