Justia Transportation Law Opinion Summaries

William D. Lunn, individually and as the representative of the estates of his three deceased children, filed a wrongful death lawsuit against Continental Motors, Inc. (CMI) in October 2009, alleging a design defect caused an airplane crash that killed his children. In September 2012, CMI made an unapportioned offer of judgment for $300,000, which Lunn rejected. After a lengthy litigation process, a jury found in favor of CMI. Lunn moved for a new trial, which the district court granted in February 2021. CMI appealed, arguing the claims were barred by the statute of repose under the General Aviation Revitalization Act. The Court of Civil Appeals (COCA) reversed the district court's decision.CMI then sought attorney's fees, claiming entitlement under the offer of judgment statute since the judgment was less than their offer. The district court denied the motion, ruling the unapportioned offer invalid. CMI appealed this decision. COCA affirmed the district court's ruling, referencing prior cases that required offers of judgment to be apportioned among plaintiffs to be valid.The Supreme Court of the State of Oklahoma reviewed the case to address whether an offer of judgment under 12 O.S.2021, § 1101.1(A) must be apportioned among multiple plaintiffs. The court held that such offers must indeed be apportioned to allow each plaintiff to independently evaluate the settlement offer. The court emphasized that unapportioned offers create confusion and hinder the plaintiffs' ability to assess the offer's value relative to their claims. Consequently, the court vacated COCA's opinion and affirmed the district court's judgment, ruling CMI's unapportioned offer invalid. View "Lunn v. Continental Motors, Inc." on Justia Law

Plaintiffs Charles and Grant Adler, through their business entity CM Adler LLC, distributed tortillas and other food products of Defendant Gruma Corporation to grocery stores in central New Jersey under a "Store Door Distributor Agreement" (SDDA). When Defendant terminated the relationship, Plaintiffs filed a lawsuit alleging retaliatory termination due to their organizing efforts with other distributors. Plaintiffs claimed violations of state and federal labor laws, including failure to pay minimum wages and unlawful deductions, and argued that the SDDA was a franchise agreement subject to New Jersey's Franchise Practices Act, which forbids termination without cause.The United States District Court for the District of New Jersey dismissed the case, concluding that Texas law governed under the SDDA and the case should proceed to arbitration. The District Court did not address the applicability of the Federal Arbitration Act (FAA) or Plaintiffs' exemption argument under 9 U.S.C. § 1. It found the parties had contracted for Texas law, under which the arbitration agreement was enforceable, and rejected Plaintiffs' bid to apply New Jersey law instead. The District Court also decided that Charles and Grant Adler, who did not sign the contract, were estopped from challenging its arbitration provision because they acted as parties to the contract when they performed the LLC’s work.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the FAA does not apply to the SDDA because Plaintiffs are transportation workers engaged in interstate commerce. The Court of Appeals found that the District Court erred in its choice-of-law analysis by failing to consider the impact of New Jersey public policies on its arbitrability ruling. The Court of Appeals vacated the order compelling arbitration and remanded for the District Court to complete the choice-of-law analysis under the correct framework and to reevaluate whether the individual Plaintiffs, who did not sign the arbitration agreement, are bound by its terms. View "Adler v. Gruma Corporation" 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

Christopher Ray was observed by a Cumberland Police Department officer riding his bicycle slightly to the left of the white fog line on Tuttle Road. The officer, traveling behind Ray and another cyclist, instructed them to ride single file. Ray responded with an expletive, prompting the officer to stop them and issue Ray a violation summons for failing to keep to the right of the road, as required by 29-A M.R.S. § 2063(2).Ray contested the violation, and a bench trial was held in the District Court (Portland). The court found Ray had committed the traffic infraction of not operating his bicycle on the right portion of the way as far as practicable and imposed a fine of $151. Ray appealed the decision to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court reviewed the case de novo, focusing on the interpretation of 29-A M.R.S. § 2063(2). The Court found the statute ambiguous regarding where cyclists must operate when the command to ride to the right applies. The Court noted that the terms "roadway" and "way" were not clearly defined, and the statute's language left it up to the cyclist to determine what was safe, making enforcement difficult. The Court concluded that the ambiguity must be resolved in favor of Ray, vacated the adjudication, and remanded the case for entry of judgment in favor of Ray. View "State of Maine v. Ray" on Justia Law

Timothy Hoffstead, a canine handler for Metra, was suspended after testing positive for amphetamines and opioids during a random drug test. Hoffstead attributed the positive result to his prescribed medications for ADD, migraines, and a wrist injury. The medical review officer (MRO) attempted to contact Hoffstead for an explanation but was unsuccessful. Consequently, Hoffstead was suspended and later not considered for an open canine handler position. Despite providing proof of his prescriptions and having his test results revised to negative, Metra required him to complete a rehabilitation program. Hoffstead eventually returned to work but left Metra for other employment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Metra. The court found that Hoffstead failed to demonstrate that Metra's actions were due to his disability. The court also ruled that it could not consider Hoffstead's claim regarding the exercise of seniority under the collective bargaining agreement (CBA) due to the Railway Labor Act (RLA), which prohibits courts from interpreting CBAs.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Hoffstead did not provide sufficient evidence to show that Metra's actions were motivated by his disability. The court noted that Hoffstead's failure to respond to the MRO and his decision to waive an investigation in favor of the rehabilitation program were the primary reasons for Metra's actions. The court also found that the RLA did not preclude adjudicating Hoffstead's claim regarding the seniority rules but concluded that Hoffstead failed to demonstrate a link between his disability and Metra's actions. View "Hoffstead v Northeast Illinois Regional Commuter Railroad Corp" 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 2019, fourth-grader D.J. was attending KIPP Victory Academy, which had contracted with First Student, Inc. to transport students. On October 23, 2019, substitute bus driver Tomika Richardson dropped D.J. off at the wrong corner of an intersection. The next day, Richardson again dropped D.J. off at the same incorrect location. As D.J. crossed the street, a vehicle maneuvered around the bus and struck him, causing injuries. The hit-and-run driver was never identified. D.J., through his mother, sued First Student and Richardson, alleging negligence.The case went to trial in the Circuit Court of St. Louis. The jury found in favor of Richardson on one count but ruled in favor of D.J. on another count, awarding $1.3 million in damages. The circuit court overruled First Student's motions for judgment notwithstanding the verdict (JNOV) and a new trial, leading to First Student's appeal.The Supreme Court of Missouri reviewed the case. The court held that the criminal act of the hit-and-run driver was an intervening and superseding cause, breaking the causal chain and relieving First Student of liability. The court determined that D.J. failed to prove that First Student's actions were the proximate cause of his injuries. Consequently, the Supreme Court of Missouri vacated the circuit court's judgment and remanded the case with instructions to enter judgment in favor of First Student. View "D.J. v. First Student, Inc." on Justia Law

An environmental group, Conservation Law Foundation (CLF), sued Academy Express, LLC (Academy), a transportation company, alleging that Academy violated the Clean Air Act (CAA) by idling its buses beyond state limits in Massachusetts and Connecticut. CLF claimed that its members were harmed by breathing polluted air from Academy's buses. Academy moved for summary judgment, arguing that CLF lacked associational standing. The district court agreed and granted Academy's motion, holding that CLF could not demonstrate that its members suffered a concrete injury traceable to Academy's conduct.The United States District Court for the District of Massachusetts found that only two of CLF's members, Wagner and Morelli, had alleged injuries-in-fact, but their injuries were not traceable to Academy's idling due to the presence of other potential pollution sources in the urban environment. The court did not address the standing of additional members disclosed by CLF after the close of fact discovery or the expert testimony submitted by CLF.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's narrow interpretation of injury-in-fact. The appellate court held that breathing polluted air and reasonable fear of health effects from pollution are cognizable injuries. It also found that recreational harms do not require a change in behavior to be considered injuries-in-fact. The court emphasized that traceability does not require a conclusive link but can be established through geographic proximity and expert testimony.The First Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. The district court was instructed to determine the scope of the record, make necessary factual findings, and apply the correct legal standards for injury-in-fact and traceability. The appellate court did not address redressability, leaving it for the district court to consider if necessary. View "Conservation Law Foundation, Inc. v. Academy Express, LLC" on Justia Law

Great Plains Trucking Inc. and Lennis H. Beck (defendants) appealed a circuit court judgment in favor of Carrie S. Schultz and Robert C. Schultz, Sr. (plaintiffs), surviving parents of Robert C. Schultz, Jr., in a wrongful death action. Beck, a truck driver for Great Plains, collided with the plaintiffs' vehicle, resulting in the death of their son. The collision occurred in Wentzville, Missouri, under dark and rainy conditions. The plaintiffs' vehicle had fishtailed and was struck by another vehicle before Beck's truck collided with it.The Circuit Court of St. Charles County held a jury trial, which resulted in a verdict awarding the plaintiffs $10,000,000 in compensatory damages, $10,000,000 in aggravating circumstances damages against Great Plains, and $25,000 in aggravating circumstances damages against Beck. The circuit court entered judgment in accordance with the jury's verdicts and awarded post-judgment interest. The defendants filed a post-trial motion for a new trial or judgment notwithstanding the verdict, which the circuit court overruled. The defendants then appealed.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court found that the defendants did not preserve their claims of error for appellate review or that their preserved claims failed on the merits. Specifically, the court held that the defendants failed to preserve the issue of excluding expert testimony regarding the mother's impairment by THC because they did not object at trial. Additionally, the court found that the defendants did not preserve their objection to the participation of separate counsel for the plaintiffs throughout the trial.The court also held that there was substantial evidence to support the jury's finding that Beck failed to keep a careful lookout and that the jury's award of aggravating circumstances damages against both Beck and Great Plains was supported by sufficient evidence. The court concluded that Beck's multiple violations of the Missouri CDL manual and Great Plains' acceptance of Beck's conduct demonstrated complete indifference or conscious disregard for the safety of others. View "Schultz vs. Great Plains Trucking, Inc." on Justia Law

Andre Le Doux was driving on Interstate 81 in Virginia when he encountered a sudden traffic standstill due to a torrential downpour. As he braked, a vehicle behind him pushed his van into another vehicle, leaving his van exposed in the left lane. Ervin Worthy, driving a Western Express tractor trailer, saw the heavy rain and braked, but could not stop in time and collided with Le Doux’s van, causing severe injuries to Le Doux.Le Doux sued Worthy for negligence and willful and wanton negligence, and Western Express for vicarious liability and negligent hiring. The United States District Court for the Western District of Virginia excluded expert testimony from Le Doux’s meteorologist and accident reconstructionist due to gaps in radar data and inaccurate GPS timestamps. The court also excluded testimony from Le Doux’s trucking expert, finding it unnecessary for the jury to understand the standard of care for a tractor trailer driver in rainy conditions. Additionally, the court dismissed Le Doux’s negligent hiring claim against Western Express, reasoning that since Worthy was acting within the scope of his employment, the claim was redundant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of the expert testimonies, agreeing that the gaps in data and potential jury confusion justified the decision. The court also upheld the exclusion of the trucking expert’s testimony, finding that the jury could understand the necessary standard of care without it. Finally, the court affirmed the dismissal of the negligent hiring claim, holding that since the jury found Worthy not negligent, Western Express could not be liable for negligent hiring. The Fourth Circuit concluded that the district court did not abuse its discretion in its rulings. View "Le Doux v. Western Express, Inc." on Justia Law