Justia Transportation Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the decision of the Iowa Department of Transportation (DOT) to rescind Petitioner's license under Iowa Code 322.3(12), holding that there was substantial evidence to revoke the motor vehicle dealer license.Petitioner, who owned and operated a vehicle dealership, pleaded guilty to one count of structuring transactions to avoid mandatory reporting requirements in violation of 31 U.S.C. 5324(a)(1) and (3) and was sentenced to a term of probation. The DOT then revoked Petitioner's Motor Vehicle Dealer License for a period of five years because of the structuring conviction. The district court upheld the revocation, stayed enforcement of the license revocation until the completion of the appeal, and tolled the entirety of the five-year revocation period. The court of appeals upheld the license revocation but determined that the district court lacked the authority to toll the five-year license revocation period. The Supreme Court held (1) there was substantial evidence to revoke the motor vehicle dealer license; and (2) the revocation period shall be extended by the length of the stay. View "Carreras v. Iowa Department of Transportation, Motor Vehicle Division" on Justia Law

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The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court affirming the decisions of the administrative law judge (ALJ) and the Iowa Department of Transportation (DOT) that good cause existed to permit a franchiser to create dueling franchises in a geographic area under Iowa Code 322A.4, holding that the district court did not err in its judgment.At issue was whether, in considering if the establishment of an additional franchisee in a geographic area is in the public interest, the DOT must consider the investment and impacts across the entire geographic area of the existing franchisee. The ALJ and DOT concluded that the twenty-three county area where the additional franchisee would compete with the existing franchisee was the relevant geographic area to consider when determining the presence of good cause under section 322A.4. The court of appeals reversed, arguing that the relevant geographic area to consider was the entire seventy-one county area in which the existing franchise conducted business. The Supreme Court vacated the decision below and affirmed the trial court, holding that the proper focus was the area in which the existing franchisee and the proposed new franchise would be in direct competition. View "Sioux City Truck Sales, Inc. v. Iowa Department of Transportation" on Justia Law

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The Supreme Court vacated the decision of the court of appeals declining to give preemptive effect to a no-hazard determination by the Federal Aviation Administration (FAA) and affirmed as modified the judgment of the district court, holding that the Federal Aviation Act allows for local zoning regulation, and the FAA's no-hazard letter did not preempt the local airport zoning regulations as a matter of law.A farmer built a twelve-story grain leg near an airport. The airport commission informed the farmer he needed a variance and refused to grant one. Thereafter, the FAA approved the structure. The local commissioners later brought this action in equity to force the farmer to modify or remove the structure. The district court issued an injunction. The court of appeals affirmed. The Supreme Court granted further review and held (1) state and local regulators can impose stricter height restrictions on structures in flight paths notwithstanding an FAA no-hazard determination, and therefore, the no-hazard letter did not preempt the local airport zoning regulations; and (2) the district court properly found that the structure constituted a threat to aviation requiring abatement, but the $200 daily penalty is vacated and the judgment is modified to require the farmer to abate the nuisance within nine months of this opinion. View "Carroll Airport Commission v. Danner" on Justia Law

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The Supreme Court reversed the decision of the district court denying Defendant’s motion to suppress evidence resulting from a stop by an Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officer, holding that the IDOT MVE lacked the authority to stop and arrest Defendant.The MVE in this case stopped Defendant for speeding in a construction zone. After determining that Defendant’s driver’s license had been revoked the MVE arrested Defendant and took him to jail. Defendant was convicted of driving while revoked. On appeal, Defendant argued that IDO MVE officers lacked authority at the time he was stopped to engage in general traffic enforcement under Iowa Code chapter 321 and that the stop and arrest could not be sustained as a citizen’s arrest under Iowa Code 804.9. The Supreme Court agreed, holding that today’s decision in Rilea v. Iowa Department of Transportation, __ N.W.2d ___ (Iowa 2018), required that Defendant’s conviction be vacated and this case remanded for further proceedings. View "State v. Werner" on Justia Law

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The Supreme Court held tha before May 11, 2017, Iowa Department of Transportation (IDOT) Motor Vehicle Enforcement (MVE) officers lacked authority to stop vehicles and issue speeding tickets or other traffic citations unrelated to operating authority, registration, size, weight, and load.In 2016, two motorists were separately cited by MVE officers for speeding in a construction zone. In declaratory order proceedings, the IDOT concluded that MVE officers possessed authority to stop vehicles and issue these citations. The district court reversed. The Supreme Court affirmed, holding that, prior to May 11, 2017, IDOT peace officers were conferred only limited authority by chapter 321 of the Iowa Code to enforce violations relating to operating authority, registration, size, weight, and load of motor vehicles and trailers. View "Rilea v. Iowa Department of Transportation" on Justia Law

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At issue was whether property owners’ state-law damage claims against the railroad bridge owners alleging that the design and operation of the railroad bridges resulted in flood damage to other properties were preempted by the Federal Interstate Commerce Commission Termination Act (ICCTA), 49 U.S.C. 10501(b).Plaintiffs, property owners in Cedar Rapids, sued the owners of certain railroad bridges across the Cedar River alleging that their efforts to protect the bridges from washing out exacerbated the effects of the 2008 flooding for other property owners. The district court granted Defendants’ motion for judgment on the pleadings, concluding that the ICCTA expressly preempted Plaintiffs’ state law claims. The Supreme Court affirmed, holding that the ICCTA did indeed preempt Plaintiffs’ action. View "Griffioen v. Cedar Rapids" on Justia Law

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The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary roads.The enforcement of the IDOT’s rules resulted in three cities being ordered to relocate or remove several of their ATE cameras. The district court upheld both the IDOT’s rules and its decisions based on those rules. The Supreme Court reversed, holding that the rules were invalid and could not be enforced against the cities because the IDOT’s specific grants of authority did not support the rules. View "City of Des Moines v. Iowa Department of Transportation" on Justia Law

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The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary roads.The enforcement of the IDOT’s rules resulted in three cities being ordered to relocate or remove several of their ATE cameras. The district court upheld both the IDOT’s rules and its decisions based on those rules. The Supreme Court reversed, holding that the rules were invalid and could not be enforced against the cities because the IDOT’s specific grants of authority did not support the rules. View "City of Des Moines v. Iowa Department of Transportation" on Justia Law