MA Delivery Ass’n v. Coakley

The Massachusetts Delivery Association claimed that a state law is preempted as to motor carriers under the Federal Aviation Administration Authorization Act of 1994, 108 Stat. 1569, which expressly preempts state attempts to regulate "a price, route, or service of any motor carrier," The challenged state law, part of Mass. Gen. Laws ch. 149, sect. 148B(a)(2), which requires that an individual performing a service for another be classified as an employee unless "the service is performed outside the usual course of the business of the employer." The MDA also claimed that the state statute imposes an undue burden which violates the Commerce Clause. The district court found that Younger abstention was appropriate because, while the Association is not itself a party to relevant state litigation, three of its members are defendants in state civil proceedings brought not by the Attorney General (defendant in this case) but by private parties. The First Circuit remanded for the court to exercise jurisdiction, concluding that any decision will not interfere with pending state cases. View "MA Delivery Ass'n v. Coakley" on Justia Law