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In reaching its decision, the Court relied on the doctrine of "presumption against preemption," stating that "when the test of a pre-emption clause is susceptible of more than one plausible reading, courts ordinarily 'accept the reading that disfavors pre-emption.'" 128 However, as the dissent emphasized, the Court's reliance on this doctrine has waned in recent preemption cases, citing decisions such as Rowe v