Justia Transportation Law Opinion Summaries

A United States citizen, formerly known as Paul Anderson and now Saadiq Long, was placed on the federal government’s Terrorist Screening Dataset (commonly called the Terrorist Watchlist) and, at one point, on its No Fly List subset. After experiencing travel restrictions, employment issues, and other alleged harms, Long challenged his placement on these lists, asserting constitutional and statutory violations. He claimed that his inclusion was based on impermissible factors such as race, religion, and protected activities, and that the government’s information-sharing practices and redress procedures were unlawful. While the litigation was ongoing, Long was removed from the No Fly List, but remained on the broader Watchlist. He also alleged that his Watchlist status led to the denial of credentials necessary for his work as a truck driver.The United States District Court for the Eastern District of Virginia initially transferred some of Long’s claims to the Fourth Circuit and stayed others. After Long’s removal from the No Fly List, a prior Fourth Circuit panel found his No Fly List claims moot and remanded for the district court to determine which claims remained justiciable. On remand, the district court dismissed all of Long’s claims for lack of subject matter jurisdiction, finding that his removal from the No Fly List mooted those claims and that he lacked standing for his Watchlist-related claims, as his alleged injuries were either resolved or not sufficiently imminent.The United States Court of Appeals for the Fourth Circuit vacated the district court’s dismissal. The Fourth Circuit held that, in light of the Supreme Court’s decision in FBI v. Fikre, Long’s removal from the No Fly List did not necessarily moot his claims, as the government had not shown it could not repeat the challenged conduct. The court also found that Long had standing to challenge his Watchlist status based on the denial of transportation credentials, and remanded for the district court to consider the merits of his claims. View "Long v. Bondi" on Justia Law

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt.The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law

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

A business owner and his company, which provides non-emergency medical transportation, challenged the constitutionality of a Nebraska statute requiring a showing of "public convenience and necessity" to obtain a certificate to operate such services. They argued that the statute violated the Nebraska Constitution's due process, special legislation, and special privileges and immunities clauses. They claimed the requirement protected existing providers from competition and harmed the public by reducing service quality.The district court for Lancaster County rejected their constitutional challenges and dismissed their complaint. The court applied a rational basis test to the due process claim, finding the statute rationally related to a legitimate state interest in preventing destructive competition and ensuring reliable transportation services. The court also found the statute did not create an arbitrary or unreasonable classification or a closed class, thus rejecting the special legislation claim. Finally, the court determined the statute did not grant irrevocable special privileges or immunities, dismissing the special privileges and immunities claim.On appeal, the Nebraska Supreme Court affirmed the district court's rejection of the facial constitutional challenges, agreeing that the statute was rationally related to a legitimate state interest and did not violate the special legislation or special privileges and immunities clauses. However, the Supreme Court vacated the district court's order to the extent it ruled on as-applied challenges, determining that such challenges should be raised in an application for certification and an appeal from any denial by the Public Service Commission. View "N'Da v. Golden" on Justia Law

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content.The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors.The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed.Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law

Mendocino Railway, a California corporation, owns and operates a railroad line known as the "Skunk Train" between Fort Bragg and Willits, California. The City of Fort Bragg and the California Coastal Commission sought to regulate the use and maintenance of the Railway's properties within the City, which the Railway resisted, claiming federal preemption under the Interstate Commerce Commission Termination Act (ICCTA). The City filed a state court action seeking declaratory and injunctive relief to compel the Railway to comply with local regulations. The Railway argued that federal law preempted these local regulations. Subsequently, the Railway filed a federal lawsuit seeking a declaration that the City's and Commission's regulatory actions were preempted by federal law and an injunction to prevent interference with its operations.The Mendocino County Superior Court overruled the Railway's demurrer, which argued that federal law preempted all local regulations. The Railway's subsequent petitions to the California Court of Appeal and the California Supreme Court were unsuccessful. The Railway then filed an answer in the state court, asserting federal preemption as an affirmative defense. Meanwhile, the Commission intervened in the state court action, seeking a declaration that the Coastal Act and local coastal program applied to the Railway's activities and were not preempted by federal law. The Railway also attempted to remove the state action to federal court, but the district court remanded it back to state court.The United States Court of Appeals for the Ninth Circuit reviewed the district court's dismissal of the Railway's federal lawsuit under the Colorado River doctrine, which allows federal courts to abstain from exercising jurisdiction in favor of parallel state court proceedings. The Ninth Circuit affirmed the district court's dismissal, finding that the state court proceedings were sufficiently parallel to the federal action and that considerations of avoiding piecemeal litigation, forum shopping, and the order in which the forums obtained jurisdiction supported the dismissal. The court held that the state court could adequately protect the Railway's rights and that the federal preemption issue could be resolved in the state court proceedings. View "MENDOCINO RAILWAY V. AINSWORTH" on Justia Law

The plaintiffs, five Muslim U.S. citizens, allege they have been placed on the Terrorist Screening Dataset, commonly known as the "terrorist watchlist." This list includes the No-Fly List, which prevents individuals from boarding flights, and the Selectee List, which subjects individuals to enhanced security screening. Four plaintiffs claim they are on the Selectee List due to repeated enhanced screenings, while one plaintiff, Adis Kovac, claims he is on both the No-Fly List and the Selectee List. Each plaintiff sought redress through the Department of Homeland Security’s Traveler Redress Inquiry Program (TRIP), but only Kovac received confirmation of his No-Fly List status.The plaintiffs filed a lawsuit in the U.S. District Court for the Northern District of Texas against various federal agency heads, alleging violations of their constitutional rights and unlawful agency action under the Administrative Procedure Act (APA). The district court dismissed several claims, including due process and equal protection claims, and later dismissed Kovac’s No-Fly List claims as moot after he was removed from the list. The remaining APA claims were addressed at summary judgment, where the district court ruled that the agencies had statutory authority to maintain the watchlist and that the TRIP procedures were not arbitrary and capricious.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that the relevant federal agencies have clear statutory authority to create, maintain, and use the watchlist for screening airline passengers. The court found that the statutory framework, including the Aviation and Transportation Security Act, the Homeland Security Act, and subsequent legislation, provided unambiguous authority for the watchlist. The court did not address whether the major questions doctrine applied, as the statutory authority was clear. The court also concluded that the plaintiffs lacked standing to challenge the watchlist’s use in contexts unrelated to airport security. View "Kovac v. Wray" on Justia Law

The case involves Salt Lake County's challenge to the constitutionality of the Aircraft Valuation Law, which provides a preferred method for determining the fair market value of aircraft for tax purposes. The County argued that the application of the law to Delta Air Lines' aircraft resulted in an assessment below fair market value, violating the Utah Constitution. The County also contended that the law, on its face, violated the Utah Constitution by divesting the Utah State Tax Commission of its power to assess airline property.The Utah State Tax Commission had previously upheld the 2017 assessment of Delta's property, which was calculated according to the Aircraft Valuation Law. The Commission found that the County did not provide clear and convincing evidence that the legislature's preferred method of valuation did not reasonably reflect fair market value.The Supreme Court of the State of Utah rejected the County's arguments. The court held that the County failed to fully utilize the statutory safety valve, which allows the Commission to use an alternative valuation method if the preferred method does not reasonably reflect fair market value. The court also rejected the County's facial challenge to the Aircraft Valuation Law, concluding that the County did not show that the law prohibits the legislature from prescribing a preferred method for valuing aircraft. Therefore, the court affirmed the Commission's decision. View "Salt Lake Co v. Tax Commission" on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law