Justia Transportation Law Opinion Summaries

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Jacob Marion, a minor, was struck and injured by a train operated by Grand Trunk Western Railroad Company while he was walking down the railroad tracks listening to music. The train's conductor and engineer saw Marion walking with his back to the train from a distance of about three-quarters of a mile. They sounded the train's horn when they were approximately 18 seconds away from Marion, but he did not respond. The emergency brake was applied only one second before the train struck Marion. Marion's guardian brought a negligence action against the railroad company and its employees. The defendants argued that the collision was not caused by their negligence but by Marion's failure to exercise ordinary care for his own safety.The trial court granted the defendants' motion for summary disposition, noting that they had attempted to alert Marion of the train's approach and that Marion was old enough to understand the dangers of trains. The plaintiff appealed this decision. The Court of Appeals reversed the trial court's decision, holding that a train engineer has a duty to stop or slow down when a person in the train’s path fails to respond to a warning signal. The defendants then sought leave to appeal to the Supreme Court.The Supreme Court of Michigan affirmed the decision of the Court of Appeals. The court held that when a train operator sees a person on the tracks, there is a presumption that the person will move to a place of safety. However, when it becomes apparent that the person will not or cannot get out of the way, that presumption is overcome, and the train operator has a duty to take steps to avoid a collision. The court found that there were genuine issues of material fact as to whether the defendants were negligent, and therefore, summary disposition was not warranted. The case was remanded to the trial court for further proceedings. View "Marion V Grand Trunk Western Railroad Company" on Justia Law

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The case involves a dispute over the duty of care owed by a common carrier, the Kanawha Valley Regional Transportation Authority (KRT), to a passenger, Sandy K. Hayes, who had safely exited the carrier's bus. After disembarking, Hayes crossed the road and was struck by another vehicle. Hayes sued KRT, arguing that it breached its duty to use the "highest degree of care" towards her. The circuit judge disagreed and granted summary judgment to KRT, finding no evidence of any duty that was breached.The Circuit Court of Kanawha County granted summary judgment in favor of KRT. The court found that KRT did not have a duty to Hayes after she flagged the stop, exited the bus, and crossed the road where she was struck by a vehicle. The court determined that KRT owed Hayes no high duty of care after she exited the bus and found no factual disputes remaining for a jury to resolve.The Supreme Court of Appeals of West Virginia affirmed the circuit court's decision. The court held that a common carrier owes the highest degree of care to a passenger who is in the act of boarding, is upon, or is in the act of disembarking from, the carrier’s vehicle. However, once a passenger safely and freely disembarks from a common carrier’s vehicle at his or her chosen destination, the carrier’s contract to safely transport the passenger ends and the former passenger assumes the status of a pedestrian. From that point, the carrier owes the former passenger only a duty of ordinary care. The court found that KRT's high duty of care ended when Hayes safely disembarked from the bus and that she offered no evidence that KRT breached its ordinary duty of care. View "Hayes v. Kanawha Valley Regional Transportation Authority" on Justia Law

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The case involves Trenton Palmer, an experienced private pilot, who was charged by the Federal Aviation Administration (FAA) for flying his plane at an altitude of less than 100 feet above ground level and within 500 feet of people, a house, and other structures. The FAA claimed that Palmer violated a regulation establishing minimum safe altitudes. An administrative law judge (ALJ) found Palmer guilty of the violation, and the National Transportation Safety Board (NTSB) affirmed the decision. Palmer appealed, arguing that the ALJ committed multiple prejudicial errors and that the complaint against him should have been dismissed.Previously, the ALJ had denied Palmer's motion to dismiss the FAA’s complaint on the ground that the complaint failed to give fair notice of the charges. The ALJ found that Palmer violated Sections 91.119(a), (c), and 91.13(a) of the FAA regulations. The ALJ mitigated Palmer’s suspension from 120 days to 60 days. Palmer appealed the ALJ’s decision to the Board and the FAA cross-appealed the ALJ’s mitigation of Palmer’s suspension. On de novo review, the Board affirmed the ALJ’s order and reversed the ALJ’s mitigation of the Administrator’s sanction because the Administrator’s selected sanction was supported by a reasonable explanation and there were no mitigating circumstances.The United States Court of Appeals for the District of Columbia Circuit upheld the decision from the NTSB. The court found that Palmer's arguments on appeal as to the Section 91.119 violations turn on whether he proved his defense that the low flight was necessary for takeoff or landing. The court rejected Palmer's claim of inadequate notice as legally unsupported and facially implausible. The court also found no error in the ALJ’s reliance on expert witness testimony and the Board’s subsequent affirmance. The court denied Palmer’s petition for review. View "Palmer v. FAA" on Justia Law

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The case involves MCR Oil Tools, L.L.C., who filed a petition for review against the United States Department of Transportation, its Secretary Pete Buttigieg, the Pipeline and Hazardous Materials Safety Administration, and William S. Schoonover in his official capacity as Associate Administrator of Hazardous Materials Safety. The petition was filed in response to an order from the Department of Transportation.The case was brought before the United States Court of Appeals for the Fifth Circuit. Prior to this, the case had been reviewed by the Department of Transportation, but the details of the lower court's proceedings and decisions are not provided in the document.The United States Court of Appeals for the Fifth Circuit granted the petition for review. The court decided to expedite the matter to the next available randomly designated regular oral argument panel. Additionally, the court ruled that the motions for stay pending review and for administrative stay should be decided by the argument panel. The court carried these motions with the case, consistent with their panel practice. However, the court did not express any opinion on the disposition of these motions. View "MCR Oil Tools v. United States Department of Transportation" on Justia Law

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In November 2021, David Goyco was struck and injured by an automobile while operating a low-speed electric scooter (LSES). Goyco filed a claim for personal injury protection (PIP) benefits under his personal automobile policy with Progressive Insurance Company. Progressive denied the claim, arguing that Goyco's LSES did not meet the definition of an "automobile" and that Goyco could not be considered a "pedestrian" under the New Jersey Automobile Reparation Reform Act, commonly known as the No-Fault Act. Goyco filed a complaint, asserting that LSES riders should be considered "pedestrians" entitled to PIP benefits under the No-Fault Act. The trial court denied relief to Goyco, and the Appellate Division affirmed.The Supreme Court of New Jersey affirmed the lower courts' decisions. The court held that an LSES rider does not fall within the definition of "pedestrian" for purposes of the No-Fault Act. The court found that Goyco's LSES was a "vehicle" that used a rechargeable electric motor and was therefore "propelled by other than muscular power" and was "designed for use on highways, rails and tracks." The court also rejected Goyco's reliance on a 2019 statute that provides that an LSES should be considered equivalent to a bicycle, stating that the statute was not intended to have any effect on the No-Fault Act. The court concluded that Goyco was not a pedestrian entitled to PIP benefits under Progressive's No-Fault insurance policy. View "Goyco v. Progressive Insurance Company" on Justia Law

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The case revolves around a dispute between Diamond Transportation Logistics (Diamond) and The Kroger Company (Kroger). In 2010, the two companies entered into a transportation agreement, which was renewed in 2016, for Diamond to transport Kroger's goods. The agreement included an indemnity provision, which allowed Kroger to withhold payments from Diamond for claims against Diamond under certain conditions. In December 2015, a subcontractor of Diamond was involved in a fatal accident while transporting Kroger's goods. The family of the deceased sued both Diamond and Kroger for wrongful death, alleging negligence in Kroger's selection, hiring, and retention of Diamond as a shipper. Kroger demanded Diamond to cover its legal expenses based on the indemnity provision in their agreement. However, Diamond failed to reimburse Kroger, leading Kroger to withhold nearly $1.8 million in shipping payments from Diamond.The case was first heard in the United States District Court for the Southern District of Ohio, where Kroger filed a counterclaim for breach of the transportation agreement's indemnity provision. The district court ruled in favor of Kroger, awarding it $612,429.45 plus interest. Diamond appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit Court of Appeals affirmed the district court's decision. The main issue was whether the indemnity provision's exception for "liability...caused by the sole negligence or willful misconduct of Kroger" relieved Diamond of its obligation. The court held that the exception did not apply in this case because Kroger's liability for the family's negligent selection, hiring, and retention claim was not caused by its "sole negligence." The court reasoned that Diamond's negligence also played a part in Kroger's liability, and therefore, Diamond was required to cover Kroger's costs in settling the family's claim. View "Diamond Transp. Logistics, Inc. v. Kroger Co." on Justia Law

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A pilot, who was injured in an airplane crash in 1985, sought medical benefits for a 2016 spinal surgery and subsequent treatment, as well as for diabetes treatment related to his spinal treatment. The Alaska Workers’ Compensation Board denied his claim, concluding that the 1985 injury was not a substantial factor in the pilot’s spinal problems. The Board also excluded the testimony of the pilot’s biomechanics expert due to non-compliance with Board regulations. The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, finding substantial evidence in the record to support the Board’s decision and that the Board had not abused its discretion in its procedural rulings.The Supreme Court of the State of Alaska affirmed the Commission’s decision. The court found that substantial evidence supported the Board's decision that the 1985 injury was not a substantial factor in the pilot's spinal problems. The court also found that the Board did not abuse its discretion by excluding the testimony of the pilot's biomechanics expert due to non-compliance with Board regulations. The court further held that the Board did not have an obligation to secure the testimony of a particular witness, and that the pilot's failure to secure a witness's testimony did not create an obligation for the Board to do so. View "Jespersen v. Tri-City Air and Alaska Insurance Guaranty Company" on Justia Law

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The defendant, Antonio Santonastaso, was convicted of making a false statement to federal investigators and attempted witness tampering. The charges stemmed from a 2018 investigation by the Federal Aviation Administration (FAA) into allegations that Santonastaso was flying a helicopter without the necessary certifications. During the investigation, Santonastaso falsely claimed that he had the requisite certifications to fly and that his previous involvement in a 2000 helicopter theft was part of an undercover operation.The case was first heard in the United States District Court for the District of Massachusetts, where Santonastaso was found guilty. He appealed the decision, arguing that the government's evidence was insufficient to prove his guilt and that the district court erred by not giving a materiality instruction based on the Supreme Court's decision in Maslenjak v. United States.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The court found that the evidence was sufficient for the jury to find Santonastaso guilty of making a false statement to federal investigators and attempted witness tampering. The court also ruled that the district court did not commit instructional error in rejecting Santonastaso's proposed materiality instruction. The court held that the law-of-the-circuit doctrine foreclosed the application of the Maslenjak materiality standard to § 1001(a) prosecutions, and that the district court's instruction correctly stated the controlling law on materiality. View "United States v. Santonastaso" on Justia Law

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The case involves Scotlynn Transport, LLC and Plains Towing and Recovery, LLC, disputing the ownership of a semi-tractor. The semi-tractor, owned by Scotlynn, was involved in an accident and subsequently towed by Plains Towing to its impound lot. After Scotlynn paid for the towing services and took possession of the trailer, the semi-tractor remained at the impound lot. Plains Towing, considered a "removal agency" under South Dakota law, sent a notice to Scotlynn and later acquired the title to the semi-tractor using the statutory procedure outlined in SDCL 32-36-8 and 32-36-9. Scotlynn initiated a lawsuit against Plains Towing, alleging several claims related to the disputed ownership of the semi-tractor.The Circuit Court of the Fourth Judicial Circuit, Meade County, South Dakota, granted Plains Towing's motion for summary judgment, concluding that Plains Towing had complied with SDCL 32-36-8 and lawfully obtained the title to the semi-tractor. Scotlynn appealed, arguing that there were genuine issues of material fact relating to claims raised in Scotlynn’s complaint that were not addressed by the court.The Supreme Court of the State of South Dakota partially reversed and affirmed the lower court's decision. The court found that there were genuine issues of material fact concerning the existence of an implied contract between the parties regarding the storage of the tractor. However, the court agreed with the lower court that the "drafting errors" Scotlynn alleged were contained in the notice would not, themselves, preclude obtaining the title under SDCL 32-36-9. The case was remanded for further proceedings consistent with the court's holdings. View "Scotlynn Transport, LLC v. Plains Towing and Recovery, LLC" on Justia Law

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The case involves James Fejes, a pilot who held a certificate issued by the Federal Aviation Administration (FAA) under 49 U.S.C. § 44703. Fejes used his aircraft to transport and distribute marijuana to retail stores within Alaska, an activity that is legal under state law but illegal under federal law. After an investigation, the FAA revoked Fejes's pilot certificate under 49 U.S.C. § 44710(b)(2), which mandates revocation when a pilot knowingly uses an aircraft for an activity punishable by more than a year's imprisonment under a federal or state controlled substance law.Fejes appealed the FAA's decision to an Administrative Law Judge (ALJ), who affirmed the revocation. He then appealed the ALJ's decision to the National Transportation Safety Board (NTSB), which also affirmed the ALJ. Throughout the agency proceedings, Fejes admitted that he piloted an aircraft to distribute marijuana within Alaska, but argued that his conduct fell outside of § 44710(b)(2)'s reach.The United States Court of Appeals for the Ninth Circuit denied Fejes's petition for review of the NTSB's order affirming the FAA's revocation of his pilot certificate. The court rejected Fejes's argument that the FAA lacked jurisdiction to revoke his pilot certificate because Congress cannot authorize an administrative agency to regulate purely intrastate commerce like marijuana delivery within Alaska. The court held that airspace is a channel of commerce squarely within congressional authority, and therefore, Congress can regulate Fejes's conduct. The court also rejected Fejes's argument that his conduct was exempt under FAA regulation 14 C.F.R. § 91.19, and that the FAA misinterpreted § 44710(b)(2). The court concluded that the FAA's revocation of Fejes's pilot certificate was not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law. View "FEJES V. FAA" on Justia Law