Justia Transportation Law Opinion Summaries
International Brotherhood of Teamsters v. Federal Motor Carrier Safety Administration
The Ninth Circuit denied petitions for review of the FMCSA's determination that federal law preempted California’s meal and rest break rules (MRB rules), as applied to drivers of property-carrying commercial motor vehicles who are subject to the FMCSA's own rest break regulations.The panel held that the agency's decision reflects a permissible interpretation of the Motor Carrier Safety Act of 1984 and is not arbitrary or capricious. Applying Chevron deference to the agency's interpretation of the statute and the phrase "on commercial motor vehicle safety," the panel held that even assuming petitioners identified a potential ambiguity in the statute, the agency's reading was a permissible one. In this case, the FMCSA reasonably determined that a State law "on commercial motor vehicle safety" is one that "imposes requirements in an area of regulation that is already addressed by a regulation promulgated under [section] 31136." Furthermore, the FMCSA's 2018 preemption decision also reasonably relied on Congress's stated interest in uniformity of regulation.The panel concluded that the FMCSA permissibly determined that California's MRB rules were State regulations "on commercial motor vehicle safety," so that they were within the agency's preemption authority. The panel also concluded that the FMCSA faithfully interpreted California law in finding that California's rules were "additional to or more stringent than" federal regulations. Finally, the panel concluded that the agency did not act arbitrarily or capriciously in finding that enforcement of the MRB rules "would cause an unreasonable burden on interstate commerce." View "International Brotherhood of Teamsters v. Federal Motor Carrier Safety Administration" on Justia Law
Ali v. Daylight Transport, LLC
Daylight, an expedited less-than-truckload carrier, contracts with independent truck drivers. Daylight’s California drivers only provided services within California. The plaintiffs each entered into an “Independent Contractor Service Agreement” before beginning to drive for Daylight and regularly signed materially identical contract extensions while driving for Daylight. All of those Agreements contained an identical arbitration provision. The plaintiffs filed a putative class action, requesting relief from Daylight’s “unlawful misclassification of former and current Daylight delivery drivers as ‘Independent Contractors,’ ” and alleging violations of Labor Code and wage order provisions, and the law against unfair competition.The court of appeal affirmed the denial of Daylight’s motion to compel arbitration, applying California law and finding the agreement procedurally and substantively unconscionable, and that severance of the unconscionable terms is not possible. Daylight was in a superior bargaining position and presented the contracts on a take it or leave it basis. The Agreement’s 120-day limitations period is substantially shorter than the statutory limits. The Agreement permits Daylight to seek a provisional judicial remedy but precludes plaintiffs from equivalent access and requires that the parties split the cost of arbitration, a cost greater than litigation filing fees. Because Daylight had waived its argument, the court did not address preemption under the Federal Arbitration Act, which“provides a limited exemption from FAA coverage to contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce (9 U.S.C. 1). View "Ali v. Daylight Transport, LLC" on Justia Law
Menges v. Dept. of Transportation
Kevyn Menges suffered catastrophic injuries in a motor vehicle accident. Menges, through her guardian ad litem Susan Menges, sued the Department of Transportation (Caltrans) for its negligent construction of an interstate off-ramp. Caltrans moved for summary judgment, asserting design immunity. The trial court granted Caltrans’s motion for summary judgment. On appeal, Menges argued: (1) design immunity should not have applied since the approved plans were unreasonable, and the construction of the interstate off-ramp did not match the previously approved design plans; (2) the trial court erred in denying her oral request for a continuance at the summary judgment hearing; and (3) Caltrans’s Code of Civil Procedure section 998 offer was unreasonable and invalid, and a portion of the cost award for expert witness fees should have been disallowed. The Court of Appeal determined none of Menges’s arguments had merit, and affirmed the judgment. View "Menges v. Dept. of Transportation" on Justia Law
Rentz v. BNSF Railway Co.
BNSF Railway Co. (“BNSF”) appealed a jury verdict and money judgment entered in favor of David Rentz. In July 2012, a tractor-trailer driven by Rentz was struck by a train operated by BNSF and train engineer, Reinaldo Guitian, Jr. The collision occurred at a public railroad grade crossing. In December 2015, Rentz sued BNSF and Guitian for personal injuries sustained during the vehicle/train collision. Guitian was subsequently dismissed as a named defendant in the action. Trial was held over eleven days in January 2019. Guitian was designated as BNSF’s party representative under N.D.R.Ev. 615 and was not sequestered from the courtroom. The jury returned a verdict finding Rentz 15% at fault and BNSF 85% at fault. A money judgment was entered in favor of Rentz. BNSF asserted it was denied a fair trial because: (1) BNSF’s designated representative at trial was allowed to be questioned beyond the scope of his knowledge; (2) video and audio clips taken from discovery depositions of BNSF’s designated representatives were improperly played during opening and closing arguments; (3) BNSF’s internal operating procedures were improperly used to modify the standard of care; and (4) opinion testimony of the investigating highway patrol trooper was excluded from evidence. Because the North Dakota Supreme Court concluded the questioning of BNSF’s representative at trial exceeded his personal knowledge and affected a substantial right, judgment was reversed and the matter remanded for a new trial. View "Rentz v. BNSF Railway Co." on Justia Law
Tompkins v. Metro-North Commuter Railroad Co.
Plaintiff, a carman for Metro-North, filed suit under the Federal Railroad Safety Act, alleging unlawful retaliation for his refusal to walk outdoors to another building in the railyard in allegedly unsafe winter conditions or, in the alternative, for his reporting those unsafe conditions to a foreman.The Second Circuit affirmed the district court's grant of Metro-North's motion for summary judgment, holding that the district court did not commit reversible error. The court adopted the "reasonableness" definition in the Sarbanes-Oxley Act context, which means that a "reasonable belief contains both subjective and objective components," and applied it in the FRSA context. The court agreed with Metro-North and the district court that plaintiff has not identified a genuine dispute of material fact over whether the walkways were safe or over the reasonableness of his own assessment. In this case, plaintiff did not submit any specific evidence to support his generalized contention that the walkways at the railyard were unsafe, other than to assert that other employees slipped as they walked. The court concluded that plaintiff's subjective assessment alone cannot create a genuine issue of material fact.The court agreed with the Seventh and Eighth Circuits and held that some evidence of retaliatory intent is a necessary component of an FRSA claim. The court considered the Eighth Circuit's Gunderson factors and concluded that plaintiff's protected activity was not a contributing factor in his discharge. Finally, the court considered plaintiff's remaining arguments and found them to be without merit. View "Tompkins v. Metro-North Commuter Railroad Co." on Justia Law
Progressive Rail Inc. v. CSX Transportation, Inc.
Siemens shipped two electrical transformers from Germany to Kentucky. K+N arranged the shipping, retaining Blue Anchor Line. Blue Anchor issued a bill of lading, in which Siemens agreed not to sue downstream Blue Anchor subcontractors for any problems arising out of the transport from Germany to Kentucky. K+N subcontracted with K-Line to complete the ocean leg of the transportation. Siemens contracted with another K+N entity, K+N Inc., to complete the land leg of the trip from Baltimore to Ghent. K+N Inc. contacted Progressive, a rail logistics coordinator, to identify a rail carrier. They settled on CSX. During the rail leg from Maryland to Kentucky, one transformer was damaged, allegedly costing Siemens $1,500,000 to fix.Progressive sued CSX, seeking to limit its liability for these costs. Siemens sued CSX, seeking recovery for the damage to the transformer. The actions were consolidated in the Kentucky federal district court, which granted CSX summary judgment because the rail carrier qualified as a subcontractor under the Blue Anchor bill and could invoke its liability-shielding provisions. The Sixth Circuit affirmed. A maritime contract, like the Blue Anchor bill of lading, may set the liability rules for an entire trip, including any land-leg part of the trip, and it may exempt downstream subcontractors, regardless of the method of payment. The Blue Anchor contract states that it covers “Multimodal Transport.” It makes no difference that the downstream carrier was not in privity of contract with Siemens. View "Progressive Rail Inc. v. CSX Transportation, Inc." on Justia Law
Thorne v. Pep Boys Manny Moe & Jack
A regulation promulgated under the National Traffic and Motor Vehicle Safety Act, 49 U.S.C. 30101, requires a tire dealer to help customers register their new tires with the manufacturer. The regulation prescribes three methods for tire dealers to help register a buyer’s tires. According to Thorne, Pep Boys failed to pursue any of the three when, or after, it sold her the tires. She sued on behalf of a class of Pep Boys customers who similarly received no tire registration assistance.The district court dismissed her complaint without leave to amend, holding that a dealer’s failure to help register a buyer’s tires in one of the three prescribed ways does not, by itself, create an injury-in-fact for purposes of Article III standing. The Third Circuit vacated and remanded for dismissal without prejudice. A district court has no jurisdiction to rule on the merits when a plaintiff lacks standing. Thorne’s benefit-of-the-bargain allegations do not support a viable theory of economic injury, and her product-defect argument ignores the statute’s defined terms. Unregistered tires are not worth less than Thorne paid and are not defective. Congress did not intend to give private attorneys general standing to redress the “injury” of unregistered tires. View "Thorne v. Pep Boys Manny Moe & Jack" on Justia Law
People v. Superior Court (Cal Cartage Transportation Express, LLC)
The Court of Appeal held that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) does not preempt application of California's ABC test, originally set forth in Dynamex Operations W. v. Superior Court (2018) 4 Cal.5th 903, and eventually codified by Assembly Bill 2257 (AB 2257), to determine whether a federally licensed interstate motor carrier has correctly classified its truck drivers as independent contractors.The court held that defendants have not demonstrated, as they must under People ex rel. Harris v. Pac Anchor Transportation, Inc. (2014) 59 Cal.4th 772, 785-87, that application of the ABC test prohibits motor carriers from using independent contractors or otherwise directly affects motor carriers' prices, routes, or services. Furthermore, nothing in Pac Anchor nor the FAAAA's legislative history suggests Congress intended to preempt a worker-classification test applicable to all employers in the state. The court granted a peremptory writ of mandate directing respondent court to vacate its order granting in part defendants' motion in limine, and enter a new order denying that motion because the statutory amendments implemented by AB 2257 are not preempted by the FAAAA. View "People v. Superior Court (Cal Cartage Transportation Express, LLC)" on Justia Law
Sorreda Transport, LLC v. United States Department of Transportation
The First Circuit denied Petitioner's petition for review of the final decision of the Federal Motor Carrier Safety Administration (the FMSCA) determining that Sorreda Transport, LLC's business safety rating was unsatisfactory, holding that the the FMSCA's findings and conclusions were supported by substantial evidence in the record and its decision denying Sorreda's petition for review was not arbitrary or capricious.After the FMSCA, an agency within the United States Department of Transportation that regulates the trucking industry, used a notice informing Sorreda of its proposed unsatisfactory rating, Sorreda appealed. The FMSCA issued a final order denying Sorreda's petition for administrative review. Sorreda then filed a timely petition for review in the First Circuit. The First Circuit denied the petition, holding that the FMSCA's findings were supported by substantial evidence and that its determination that Sorreda's business safety rating was unsatisfactory was neither arbitrary nor capricious under the applicable regulations. View "Sorreda Transport, LLC v. United States Department of Transportation" on Justia Law
Buonauito v. Gibson
The Supreme Court reversed the order of the circuit court dismissing Plaintiffs' illegal exaction suit that sought to enjoin the expenditure of highway funds collected pursuant to Amendment 91 of the Arkansas Constitution for two highway projects, holding that the circuit court erred in finding that Amendment 91 funds were legally designated for the projects.The two projects at issue were intended to improve portions of Interstate 30 and Interstate 630 in Little Rock by widening portions of the interstate highways from six lanes to eight or more lanes. The Arkansas Department of Transportation selected the projects to be funded by Amendment 91 money. Plaintiffs, Arkansas citizens and taxpayers, filed an illegal exaction lawsuit praying to enjoin the expenditure of funds for the projects, arguing that the projects were not "four-lane highway improvements," as required by Amendment 91. The circuit court found that the projects were covered by Amendment 91. The Supreme Court reversed, holding (1) the repeated reference to "four-lane highways" and the lack of a specific reference to six-lane interstate highways means the Amendment 91 funds cannot be used for six-lane interstate highways; and (2) therefore, the circuit court erred in dismissing the illegal exaction suit. View "Buonauito v. Gibson" on Justia Law