Justia Transportation Law Opinion Summaries

Thomas E. Bold, Jr. was found unconscious behind the wheel of his legally parked car in a mall parking lot. The car's engine was running, and the headlights were on. When roused by Officer Thomas Gelnett, Bold appeared intoxicated and admitted to drinking at a nearby bar. He intended to sleep in his car until he was fit to drive. Bold was arrested for DUI and refused a blood test at a medical facility. Consequently, PennDOT suspended his license for 18 months due to his refusal.Bold appealed the suspension in the Cumberland County Court of Common Pleas. During the hearing, Officer Gelnett admitted there was no evidence that Bold had driven the car while intoxicated. The court initially upheld the suspension but later reversed its decision, finding no reasonable grounds to believe Bold was in control of the vehicle's movement. The court cited the case Solomon v. PennDOT, which found insufficient grounds for suspicion when a suspect was found sleeping in a parked car with the engine running.The Commonwealth Court reversed the trial court's decision, holding that the officer had reasonable grounds to believe Bold was in actual physical control of the vehicle. The court relied on past cases where the presence of a driver in a running vehicle was deemed sufficient for reasonable grounds. However, the Supreme Court of Pennsylvania found that the circumstances did not provide reasonable grounds to believe Bold was operating or in actual physical control of the vehicle's movement. The court emphasized that the implied consent law requires some objective evidence of control over the vehicle's movement. Consequently, the Supreme Court reversed the Commonwealth Court's ruling, siding with Bold. View "Bold v. Commonwealth" on Justia Law

Yanjun Xu, a Chinese citizen and member of China’s Ministry of State Security, was convicted of conspiracy to commit economic espionage and conspiracy to steal trade secrets from multiple aviation companies over a five-year period. Xu was also convicted of attempted economic espionage by theft or fraud and attempted theft of composite fan-blade technology from GE Aviation. He was sentenced to a combined 240 months’ imprisonment. Xu appealed, seeking to vacate the judgment and remand for a new trial, arguing that the district court erred in failing to dismiss Counts 1 and 2 as duplicitous and abused its discretion in admitting expert testimony in violation of Federal Rule of Evidence 704(b). Alternatively, Xu sought to have his sentence vacated, arguing it was both procedurally and substantively unreasonable.The United States District Court for the Southern District of Ohio denied Xu’s motion to dismiss the indictment, finding that the conspiracy counts were not duplicitous as they alleged a single overarching conspiracy. The court also admitted expert testimony from James Olson, a retired CIA officer, who testified about espionage techniques and tradecraft, which Xu argued violated Rule 704(b). The court overruled Xu’s objections, finding that Olson’s testimony did not directly opine on Xu’s intent but rather described common practices in espionage.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the indictment was not duplicitous as it charged a single conspiracy with multiple overt acts. The court also found that Olson’s testimony did not violate Rule 704(b) and that any potential error was cured by the district court’s limiting instructions to the jury. Additionally, the appellate court found Xu’s sentence to be procedurally and substantively reasonable, noting that the district court properly calculated the intended loss and considered the § 3553(a) factors. The court concluded that Xu’s sentence was within the Guidelines range and not disparate compared to similarly situated defendants. View "United States v. Yanjun Xu" on Justia Law

The case involves Donald Aaron Hesser, who was charged with felony driving under the influence (DUI) after a motorcycle accident. Hesser was found unconscious at the scene and was taken to the hospital for treatment. Upon learning of Hesser's four previous DUI convictions, Montana State Trooper Daniel Arnold requested that the hospital retain a blood sample taken from Hesser. An investigative subpoena was later issued for Hesser's medical records and blood sample, which revealed a blood alcohol content of .208. Hesser pleaded guilty but reserved his right to appeal the denial of his motion to suppress the blood sample evidence.The District Court of the Eighth Judicial District, Cascade County, denied Hesser's motion to suppress the blood sample evidence. Hesser argued that Trooper Arnold lacked the authority to apply for an investigative subpoena, as only a prosecutor could do so under § 46-4-301(3), MCA. He also contended that there was insufficient probable cause for the subpoena. The District Court found that a prosecutor had sought the subpoena and that it was supported by probable cause, given Hesser's serious accident, the unexplained nature of the accident, and his prior DUI convictions.Upon review, the Supreme Court of the State of Montana affirmed the lower court's decision. The court found that there was sufficient probable cause for the issuance of the investigative subpoena. The court also determined that Trooper Arnold was authorized to request a blood draw under § 61-8-402(2)(a), MCA (2019), as Hesser, being unconscious, was considered statutorily not to have withdrawn his consent under § 61-8-402(3), MCA (2019). View "State v. Hesser" on Justia Law

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

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

Randall J. Weddle was involved in a major motor vehicle accident in Washington, Maine, which resulted in the death of two drivers. The accident involved five vehicles, one of which was engulfed in flames. Weddle, the driver of a large tractor trailer, was found to be the cause of the accident. Hospital tests revealed that Weddle had alcohol in his system and officers found a three-quarters-full whiskey bottle and a shot glass in his truck several days after the accident.Weddle was charged with two counts of manslaughter, two counts of aggravated criminal operating under the influence, one count of causing injury while operating under the influence, one count of aggravated driving to endanger, one count of driving to endanger, and eight counts of violating commercial motor carrier operator rules. The jury found Weddle guilty of all counts. The court conducted a sentencing analysis and set the basic sentence at twenty years, considering the nature and circumstances of the crime. The court set the maximum sentence at thirty years, weighing mitigating and aggravating factors. The final sentence was set at thirty years, with all but twenty-five years suspended, followed by four years of probation.Weddle appealed his sentence to the Maine Supreme Judicial Court. He argued that his sentence was unconstitutional because it was not proportioned to the offense and that it was excessively harsh. The court affirmed the sentence, concluding that the sentence was not greatly disproportionate to the offense and did not offend prevailing notions of decency. The court also found that the sentence was not excessively harsh, as the court had considered both aggravating and mitigating factors in setting the maximum sentence. View "State of Maine v. Weddle" 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

In this case, the Supreme Court of Ohio was called upon to interpret the definition of "motor vehicle" as it applied to the crime of aggravated vehicular assault. The defendant, Joshua Fork, was charged with multiple counts, including aggravated vehicular assault, after driving a Polaris under the influence of alcohol and injuring his passengers. At issue was whether the Polaris should be classified as a "motor vehicle" or a "utility vehicle."The Court ruled that the definition of "motor vehicle" in R.C. 4501.01(B), which applies to penal laws, should be used in the context of aggravated vehicular assault. It also held that the Polaris should be classified as a "utility vehicle," as defined by R.C. 4501.01(VV), based on its principal purpose, not its use at the time of the incident.The Court reasoned that the principal purpose of the Polaris, as shown by evidence and testimony, was for farm-related activities, such as hauling rocks and bags of seed, removing limbs, pulling a sprayer, and trimming trees. The Polaris's ancillary use for recreation did not affect its principal purpose.The Court concluded that, since the Polaris fit the definition of a "utility vehicle" under R.C. 4501.01(VV), the evidence admitted at trial was legally insufficient to support Fork’s convictions for aggravated vehicular assault. Consequently, the Court affirmed the judgment of the Sixth District Court of Appeals, which had reversed the trial court's judgment and vacated Fork’s convictions for aggravated vehicular assault. View "State v. Fork" on Justia Law

In this case, the plaintiff, Anila Daulatzai, was removed from a Southwest Airlines flight after the captain received information about her dog allergy and the presence of two dogs on board. Daulatzai insisted on remaining in her seat despite the captain’s decision, leading to her physical removal by Maryland Transportation Authority police officers. She was later charged with various offenses, including disorderly conduct and resisting arrest.Daulatzai filed an action against Southwest Airlines and the State of Maryland, alleging various grounds to challenge her removal from the plane and her arrest. The district court dismissed Daulatzai’s complaint for failure to state a plausible claim upon which relief could be granted. Daulatzai appealed that judgment and, while her appeal was pending, she also filed a motion in the district court under Federal Rule of Civil Procedure 60(b), seeking to file a fourth version of her complaint with the district court.The court denied her request, finding that her efforts were pursued in bad faith, that her repeated failures to cure defects in her pleadings had been prejudicial to the defendants, and that the fourth complaint would, in any event, be futile. Daulatzai appealed that ruling as well.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding that Daulatzai had failed to establish any of the grounds for relief under Rule 60(b) and that the district court did not abuse its discretion in denying Daulatzai leave to file her proposed third amended complaint. The court also found that Daulatzai had waived her challenge to the district court’s dismissal of her second amended complaint by failing to preserve it below. View "Daulatzai v. Maryland" on Justia Law

In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law