id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ihlr-2012	Davis, Mary J.	The Case Against Preemption: Vaccines & Uncertainty	2011	26	.pdf	application/pdf	12252	632	58	The Court also resisted discussing the presumption against preemption and increasingly relied on agency assessments of the role of state tort law as complementary to federal regulatory action.48 Subsequent cases display the Court’s own unease in assessing the scope of express preemption provisions. In Williamson, the Court speaking through Justice Breyer who authored Geier, concluded that state tort law did not actually conflict with the then current version of Stand- ard 208 because there was no indication that the federal agency intended to prevent States from “supplement[ing] through state tort law” federal minimum standards.	cache/ihlr-2012.pdf	txt/ihlr-2012.txt