Justia Transportation Law Opinion Summaries

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Robert Cox, acting as the personal representative and special administrator of the estate of Greta Cox, sued Total Quality Logistics, Inc. and Total Quality Logistics, LLC (collectively, TQL) for negligence under Ohio law. Cox alleged that TQL, in its role as a freight broker, negligently hired an unsafe motor carrier, Golden Transit, Inc., which resulted in a motor vehicle crash that killed his wife, Greta Cox. The crash occurred when the driver of the motor carrier, Amarjit Singh Khaira, failed to slow down in a construction zone and collided with Greta Cox's vehicle.The United States District Court for the Southern District of Ohio dismissed the case, ruling that Cox’s claims were preempted by the Federal Aviation Administration Authorization Act (FAAAA), specifically 49 U.S.C. § 14501(c). The district court found that the FAAAA preempted the state law claims because they related to the services of a broker with respect to the transportation of property and did not fall within the Act’s safety exception.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred in its interpretation of the FAAAA’s safety exception. The Sixth Circuit concluded that the safety exception, which preserves the safety regulatory authority of a state with respect to motor vehicles, includes common law claims like Cox’s negligent hiring claim. The court reasoned that such claims are genuinely responsive to safety concerns and directly involve motor vehicles and motor vehicle safety. Therefore, the court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cox v. Total Quality Logistics, Inc." on Justia Law

Several rail carriers challenged a Final Rule issued by the Surface Transportation Board (STB) that allows a railway shipper or receiver to request a "reciprocal switching agreement." This agreement requires a rail carrier with a monopoly over a certain rail line to compete with another carrier for specific rail traffic. The carriers argued that the Final Rule exceeded the STB's statutory authority under the Staggers Rail Act of 1980, which grants the agency authority to prescribe reciprocal switching. They also contended that aspects of the Final Rule exceeded the Board's ancillary powers and were arbitrary, capricious, and unsupported by the record.The STB issued the Final Rule after a notice-and-comment period, aiming to address service performance issues of Class I rail carriers, which were exacerbated by the COVID-19 pandemic. The Board held a hearing in April 2022 and required several Class I carriers to submit service recovery plans. Subsequently, the Board proposed new regulations to improve service by increasing competition, leading to the Final Rule. The rule establishes procedures for shippers or receivers to request reciprocal switching agreements if the incumbent carrier fails to meet certain performance standards.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the Final Rule exceeded the STB's statutory authority because it did not require a finding of inadequate service by the incumbent carrier before prescribing a reciprocal switching agreement. The court emphasized that the Staggers Rail Act requires such a finding to determine that a reciprocal switching agreement is "in the public interest." Consequently, the court granted the petition, vacated the Final Rule, and remanded the case to the STB for further proceedings. View "Grand Trunk Corporation v STB" on Justia Law

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo.The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment.The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

In 2016, Tucker Cianchette secured a multimillion-dollar judgment in Maine Superior Court against his father, step-mother, and two LLCs after they backed out of a 2015 agreement that would have given him sole control of a Ford dealership. Following this, in 2021, Eric and Peggy Cianchette, along with Cianchette Family, LLC, and Better Way Ford, LLC, filed a lawsuit alleging that Ford Motor Company violated state and federal laws during the failed 2015 negotiations and through false testimony by Ford employees in Tucker's 2016 suit.The 2021 lawsuit was initially filed in Maine Superior Court but was removed to the United States District Court for the District of Maine. The District Court dismissed all claims against Ford, leading the plaintiffs to appeal. The plaintiffs argued that Ford's actions during the 2015 negotiations and the 2016 lawsuit constituted violations of Maine's civil perjury statute, the Dealers Act, the federal Automobile Dealers' Day in Court Act, and also amounted to breach of contract and tortious interference with contract.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The Court of Appeals held that the plaintiffs failed to plausibly allege that Ford made any false representations or that any reliance on such representations was justified. The court also found that the plaintiffs' claims under the Dealers Act were barred by res judicata due to a prior ruling by the Maine Motor Vehicle Franchise Board. Additionally, the court concluded that the implied covenant of good faith and fair dealing did not apply to the breach of contract claims under Michigan law, as the SSA explicitly granted Ford the right to approve changes in ownership. View "Better Way Ford, LLC v. Ford Motor Company" on Justia Law

Michael Solondz, a commercial airline pilot, was diagnosed with anxiety and prescribed mirtazapine after experiencing side effects from another medication. Mirtazapine effectively managed his anxiety without significant side effects. Solondz sought medical clearance from the Federal Aviation Administration (FAA) to resume flying, but the FAA categorically disallows pilots from flying while taking mirtazapine, despite allowing conditional approvals for other antidepressants.The FAA denied Solondz's request for a Special Issuance medical certificate multiple times, citing his use of mirtazapine, anxiety, sleep apnea, optic neuritis, and a history of atrial fibrillation. Solondz provided evidence that his conditions were well-managed and that mirtazapine did not cause significant side effects. The FAA's final denial letter reiterated these reasons and added a concern about a potential malignant melanoma diagnosis, which Solondz disputed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the FAA failed to provide a reasonable explanation for categorically disallowing pilots taking mirtazapine from obtaining medical certification. The court noted that the FAA's process for conditionally approving other antidepressants involves a six-month waiting period and individualized medical assessments, which could also apply to mirtazapine.The court vacated the FAA's final denial letter and remanded the case for further explanation. The court emphasized that the FAA must articulate a clear rationale for its policy and avoid offering explanations that contradict the evidence. The petition for review was granted, and the case was remanded to the FAA for further proceedings consistent with the court's opinion. View "Solondz v. FAA" on Justia Law

In this case, the appellant, Brendan Linton, was riding his bicycle on a heavily trafficked state highway in Butler Township, Pennsylvania. The highway had one lane of travel in each direction, with a speed limit varying from 45 to 55 mph. Pennsylvania State Trooper Joshua Osche observed Linton riding his bicycle at speeds significantly lower than the posted speed limits, causing a buildup of traffic behind him. Despite multiple vehicles successfully passing Linton, Trooper Osche eventually initiated a traffic stop, citing Linton for impeding the normal and reasonable movement of traffic under Section 3364(b)(2) of the Vehicle Code.The Court of Common Pleas of Butler County found Linton guilty of violating Section 3364(b)(2), concluding that he should have moved to the berm area to allow faster-moving traffic to pass. The court imposed a $25 fine. The Superior Court of Pennsylvania affirmed the judgment, agreeing that Linton's failure to use the berm constituted a violation of the statute.The Supreme Court of Pennsylvania reviewed the case to determine whether Section 3364(b)(2) requires pedalcyclists to leave the roadway whenever faster-moving traffic approaches. The Court concluded that the statute calls for a fact-bound assessment of reasonableness, taking all relevant considerations into account. The Court held that there may be circumstances under which a factfinder could determine that the "reasonable efforts" a pedalcycle operator must exert include temporarily leaving the roadway. However, the Court rejected the rigid interpretations of both the appellant and the lower courts, emphasizing that the statute does not mandate pedalcyclists to always vacate the roadway for faster-moving traffic.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to reconsider the sufficiency of the evidence using the proper legal standard. View "Commonwealth v. Linton" on Justia Law

Nathaniel Gabriel Porter was cited for a traffic infraction under California Vehicle Code section 23123.5(a) for holding and viewing a mapping application on his wireless phone while driving. Section 23123.5(a) prohibits drivers from holding and operating a handheld wireless telephone unless it is used in a voice-operated and hands-free manner. Porter contested the citation, arguing that viewing a mapping application did not constitute "operating" the phone as defined by the statute. The traffic commissioner found Porter guilty and imposed a $158 fine.Porter appealed to the appellate division of the Santa Clara County Superior Court, which reversed his conviction. The appellate division concluded that "operating" a wireless telephone required active use or manipulation, such as talking, listening, emailing, or browsing the internet, and that merely observing GPS directions did not meet this threshold. The court suggested that the Legislature might need to amend the statute to address evolving technology and distracted driving concerns.The California Court of Appeal, Sixth Appellate District, reviewed the case to ensure uniformity in legal interpretation. The court examined the statutory language, legislative history, and public policy considerations. It concluded that "operating" under section 23123.5(a) includes all uses of a handheld phone's functions while driving, including viewing a mapping application. The court determined that the Legislature intended to prohibit all handheld phone use while driving to mitigate distracted driving risks. Consequently, the appellate division's judgment was reversed, and Porter's traffic conviction was reinstated. View "P. v. Porter" on Justia Law

A group of seven Utah counties, known as the Seven County Infrastructure Coalition, applied to the U.S. Surface Transportation Board for approval to construct an 88-mile railroad line in Utah's Uinta Basin. This project aimed to connect the oil-rich region to the national freight rail network, facilitating crude oil transportation to Gulf Coast refineries. The Board prepared a 3,600-page Environmental Impact Statement (EIS) addressing the project's significant environmental effects and feasible alternatives. However, the EIS did not fully analyze the potential environmental impacts of increased upstream oil drilling and downstream oil refining.The U.S. Court of Appeals for the D.C. Circuit reviewed the case after petitions were filed by a Colorado county and several environmental organizations. The D.C. Circuit found numerous violations of the National Environmental Policy Act (NEPA) in the EIS, specifically criticizing the Board for not sufficiently analyzing the environmental effects of upstream oil drilling and downstream oil refining. Consequently, the D.C. Circuit vacated both the EIS and the Board's final approval order for the railroad line.The Supreme Court of the United States reviewed the case and reversed the D.C. Circuit's decision. The Court held that the D.C. Circuit failed to afford the Board the substantial judicial deference required in NEPA cases. The Supreme Court clarified that NEPA requires agencies to focus on the environmental effects of the proposed project itself, not on separate projects that are distinct in time or place. The Court concluded that the Board's EIS complied with NEPA's procedural requirements by addressing the environmental effects of the 88-mile railroad line, without needing to evaluate the impacts of upstream oil drilling or downstream oil refining. The case was remanded for further proceedings consistent with this opinion. View "Seven County Infrastructure Coalition v. Eagle County" on Justia Law

In 2019, the Vermont Agency of Transportation (AOT) increased the rental fees for hangar space at state-owned airports. Five tenants, who own hangar facilities at the Northeast Kingdom International Airport and the Stowe-Morrisville State Airport, appealed the rate increases to the Transportation Board. They argued that the rent increase did not comply with the terms of their leases and was arbitrary. The leases allowed AOT to adjust rent based on the Consumer Price Index for All Urban Consumers (CPI-U), current market value for the land, and maintenance costs for the airport. The tenants contended that AOT improperly considered changes outside the previous lease term.The Transportation Board consolidated the tenants' appeals and reviewed the administrative records and memoranda submitted by both parties. The Board found that AOT had invested significantly in airport improvements and conducted a market-value analysis for leased space. However, the Board noted that details of the analysis were not included in the administrative record. The Board concluded that AOT was permitted to consider changes to market value and maintenance costs outside of the prior lease term but admonished AOT to provide a clearer analysis in the future.The tenants appealed to the Vermont Supreme Court, arguing that the rent increases were arbitrary and capricious due to a lack of transparent methodology. The Supreme Court affirmed the Board's conclusion that AOT could consider changes outside the prior lease term but reversed and remanded the decision concerning the fairness of the rent increases. The Court held that the Board should have sought a complete record from AOT to determine whether the rent levels were fair and conducted a new adjudication consistent with this opinion. View "In re State Airport Hangar Lease Disputes" on Justia Law