Justia Transportation Law Opinion Summaries

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

The case involves a challenge to a rule promulgated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2020, which authorized the transportation of liquefied natural gas (LNG) by rail in newly designed tank cars without requiring a permit. LNG is a hazardous material that poses significant risks if released, including explosions, fires, and the formation of ultra-cold gas clouds. The rule did not limit the number of LNG tank cars per train or set a mandatory speed limit, raising safety concerns among various stakeholders.The rule was challenged by a coalition of environmental nonprofits, several states, and the Puyallup Tribe of Indians. They argued that PHMSA did not adequately consider the safety risks and that the National Environmental Policy Act (NEPA) required the preparation of an Environmental Impact Statement (EIS). The petitioners contended that the decision not to prepare an EIS was arbitrary and capricious.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that PHMSA's decision not to prepare an EIS was indeed arbitrary and capricious. The court noted that transporting LNG by rail poses a low-probability but high-consequence risk of derailment, which could result in catastrophic environmental impacts. The court emphasized that PHMSA failed to adequately consider the probability and potential consequences of such accidents and did not impose sufficient safety measures, such as a mandatory speed limit or a cap on the number of LNG tank cars per train.The court held that PHMSA's failure to prepare an EIS violated NEPA and vacated the LNG Rule, remanding the case to PHMSA for further proceedings. The court's decision underscores the importance of thoroughly assessing environmental risks and adhering to NEPA's requirements in rulemaking processes. View "Sierra Club v. DOT" on Justia Law

The City and County of San Francisco and the San Francisco County Transportation Authority challenged a decision by the Public Utilities Commission (PUC) to issue a phase I driverless autonomous vehicle (AV) deployment permit to Waymo, LLC for fared passenger service in San Francisco and parts of San Mateo County. The petitioners argued that the PUC failed to follow the law and disregarded significant public safety issues. However, the record showed that the PUC considered and responded to the safety concerns raised by the petitioners, noting that few incidents involved Waymo driverless AVs, each was minor, and none involved injuries.The PUC had previously issued a decision establishing a pilot program for the regulation of AV passenger carriers, which included both drivered and driverless AVs. The petitioners participated in these proceedings but did not challenge the decision at that time. Waymo submitted an advice letter in December 2022 seeking a phase I driverless AV deployment permit, which was protested by the San Francisco entities. The PUC's Consumer Protection and Enforcement Division circulated a draft resolution authorizing Waymo's permit, and after considering comments and holding meetings, the PUC issued a final resolution in August 2023, authorizing Waymo to provide fared driverless AV service.The California Court of Appeal reviewed the case and found that the PUC acted within its authority and did not abuse its discretion. The court noted that the PUC's decision was supported by substantial evidence, including data showing that Waymo driverless AVs had not been involved in any collisions resulting in injuries. The court also upheld the PUC's use of the advice letter process, as it was authorized by the PUC's prior decision. The court denied the relief requested by the petitioners, affirming the PUC's decision to issue the phase I driverless AV deployment permit to Waymo. View "City and County of San Francisco v. Public Utilities Commission" on Justia Law