Justia Transportation Law Opinion Summaries

Articles Posted in New York Court of Appeals
by
The Court of Appeals held that warrantless inspections authorized by New York regulations adopting a rule promulgated by the Federal Motor Carrier Safety Administration (FMCSA) requiring the installation of electronic logging devices (ELD) in commercial motor vehicles fell within the administrative search exception to the warrant requirement.The FMCSA promgulated the rules at issue in 2015, and the rules were permanently incorporated into New York law in 2019. Petitioner commenced this combined N.Y. C.P.L.R. 78 proceeding and declaratory judgment action challenging New York's adoption of the rule. Supreme Court granted Respondents' motion to dismiss, concluding that the searches authorized by the rule were valid under the exception to the warrant requirement for administrative searches. The appellate division affirmed. The Court of Appeals affirmed as modified, holding (1) the lower courts properly determined that the ELD rule is constitutional; but (2) Supreme Court should have declared the rights of the parties rather than dismissing the complaint. View "Owner Operator Independent Drivers Ass'n v. N.Y. State Dep't of Transportation" on Justia Law

by
The Court of Appeals affirmed the judgment of the Appellate Division dismissing Plaintiffs' claims that Taxi and Limousine Commission and New York City breached the implied covenant of good faith and fair dealing and engaged in deceptive business practices under N.Y. Gen. Bus. Law 349, holding that Plaintiffs failed to state a claim.Plaintiffs, entities that purchased government licenses to operate taxis at an auction, brought this action alleging that Defendants (1) breached the implied covenant of good faith and fair dealing by failing to enforce certain licensing requirements against smartphone applicate-based competitors such as Uber Technologies, Inc. and Lyft, Inc.; and (2) engaged in deceptive business practices in their promotion of the auction. Supreme Court granted in part Defendants' motion to dismiss. The Appellate Division reversed in part and concluded that both claims should be dismissed. The Court of Appeals affirmed, holding (1) Plaintiffs did not adequately plead a claim for breach of the implied covenant of good faith and fair dealing; and (2) Plaintiffs failed to plead the type of conduct covered by N.Y. Gen. Bus. Law 349. View "Singh v. City of New York" on Justia Law

by
Plaintiff filed an action alleging that Defendants committed fraud and negligence when performing and evaluating a random drug test that Plaintiff was required to take as an airline pilot. The United States Court of Appeals for the Second Circuit certified two questions of New York law to the New York Court of Appeals. The Court accepted the questions and answered (1) drug testing regulations and guidelines promulgated by the Federal Aviation administration and the Department of Transportation do not create a duty of care for drug testing laboratories and program administrators under New York negligence law; and (2) a plaintiff may not establish the reliance element of a fraud claim under New York law by showing that a third party relied on a defendant’s false statements resulting in injury to the plaintiff. View "Pasternack v. Lab. Corp. of Am. Holdings" on Justia Law