Justia Transportation Law Opinion Summaries
Articles Posted in Transportation Law
American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority
In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law
Malco Enterprises of Nevada, Inc. vs. Woldeyohannes
Sky Moore rented a car from Budget Car and Truck Rental of Las Vegas, owned by Malco Enterprises of Nevada, Inc. Sky named Daniel Moore as an additional driver, who later rear-ended Alelign Woldeyohannes while intoxicated. Alelign sued Daniel for negligence and Malco for negligent entrustment. Daniel did not respond, resulting in a default judgment against him. The case proceeded to arbitration, where Alelign was awarded $32,680.26. Malco requested a trial de novo, leading to a short trial where the judge entered a default judgment against Daniel for $37,886.82.Alelign moved to apply the default judgment against Malco under NRS 482.305(1), which holds short-term lessors liable for damages if they fail to provide minimum insurance coverage. Malco opposed, arguing that NRS 482.305 is preempted by the Graves Amendment, which prohibits states from holding vehicle lessors vicariously liable without negligence or wrongdoing. The short trial judge granted Alelign’s motion, and the district court affirmed, concluding that NRS 482.305 is a financial responsibility law preserved by the Graves Amendment’s savings clause.The Supreme Court of Nevada reviewed the case and affirmed the district court’s judgment. The court held that NRS 482.305 is not preempted by the Graves Amendment because it is a financial responsibility law preserved by the savings clause under 49 U.S.C. § 30106(b). The court emphasized that NRS 482.305 imposes a legal requirement for lessors to provide minimum coverage, rather than a mere financial inducement, and does not impose strict vicarious liability on lessors. View "Malco Enterprises of Nevada, Inc. vs. Woldeyohannes" on Justia Law
Brock v. Flowers Foods
Angelo Brock, an independent distributor for Flowers Baking Co. of Denver, LLC, filed a class-action lawsuit alleging wage and hour violations under the Fair Labor Standards Act and Colorado labor law. Brock claimed that Flowers misclassified its delivery drivers as independent contractors to avoid paying proper wages. Flowers moved to compel arbitration based on an Arbitration Agreement within the Distributor Agreement between Brock and Flowers. The district court denied the motion, leading to this appeal.The United States District Court for the District of Colorado found that Brock fell within the "transportation workers exemption" under § 1 of the Federal Arbitration Act (FAA), which exempts certain transportation workers from arbitration. The court concluded that Brock's class of workers, who deliver Flowers goods intrastate, are engaged in interstate commerce because they play a direct and necessary role in the flow of goods across state lines. The court also determined that the Arbitration Agreement did not allow for arbitration under Colorado law, as it was inconsistent with the FAA.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The Tenth Circuit agreed that Brock's class of workers is engaged in interstate commerce, as their intrastate deliveries are part of a continuous interstate journey of goods. The court found that Flowers retains significant control over Brock's operations, indicating that the goods' delivery to retail stores is the final leg of an interstate route. The court declined to review Flowers's argument that the Distributor Agreement is not a contract of employment, as it was not raised in the lower court. Additionally, the court determined it lacked jurisdiction to review the district court's denial of arbitration under Colorado law. View "Brock v. Flowers Foods" on Justia Law
Stribling Equipment, LLC v. Eason Propane, LLC
Eason Propane, LLC, purchased a new Freightliner propane delivery truck, which caught fire due to Empire Truck Sales, LLC's negligence during repairs. The fire caused significant damage to the truck, leading to extensive business losses for Eason Propane. Eason Propane sued Empire, seeking damages for the truck's diminished value, repair costs, lost profits, and other consequential damages.The case was tried in the Lamar County Circuit Court, where the jury found Empire liable and awarded Eason Propane $263,443.39 in damages. Empire moved for a new trial on damages or a remittitur, arguing that the jury's award was against the overwhelming weight of the evidence. The trial court denied Empire's motion, leading to this appeal.The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decision. The court held that the jury's damages award was not manifestly unjust or so excessive as to shock the conscience. The court found that the evidence presented at trial supported the jury's findings, including the testimony of Eason Propane's experts regarding the truck's diminished value and lost profits. The court emphasized that it was within the jury's purview to weigh the credibility of the competing testimonies and evidence.The court concluded that the trial court did not abuse its discretion in denying Empire's motion for a new trial or remittitur. The jury's award of $112,698.46 for the truck's diminished value, $24,744.93 for repair costs, $120,000 for lost profits, and $6,000 for other consequential damages was affirmed. View "Stribling Equipment, LLC v. Eason Propane, LLC" on Justia Law
WATSON v. BNSF RAILWAY COMPANY
In August 2014, a train operated by BNSF Railway Company collided with a pickup truck driven by Paul Watson at a railroad crossing in Pawnee County, Oklahoma. Watson, who was not wearing a seatbelt, died instantly, while his wife Terri and their minor child, both belted, survived with injuries. Terri Watson, on behalf of herself, her child, and as a representative of her deceased husband's estate, filed a wrongful death and personal injury lawsuit against BNSF, alleging negligent maintenance of the crossing and failure to install adequate safety features.The case went to trial, and after three weeks of testimony and evidence, the jury found in favor of BNSF on all claims. The plaintiffs' motion for a new trial was denied by the trial court. On appeal, the Court of Civil Appeals, Division IV, found prejudicial errors in the jury instructions, specifically noting that the instructions were biased in favor of BNSF and required an excessive degree of care from Watson. The appellate court reversed the trial court's decision and remanded the case for a new trial.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The court found that the jury instructions, when considered as a whole, were not so prejudicial as to mislead the jury. The court noted that the instructions accurately reflected Oklahoma law and did not impose a higher standard of care on Watson than required. Consequently, the Supreme Court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's judgment, and reinstated the jury's verdict in favor of BNSF. The case was remanded for further proceedings consistent with this opinion. View "WATSON v. BNSF RAILWAY COMPANY" on Justia Law
Bonnet v. Whitaker
Two pilots, Luis F. Bonnet and Carlos R. Benítez Maldonado, were employed by Benítez Aviation, Inc. (BAI), which managed a Cessna aircraft. In April and May 2019, Bonnet and Benítez piloted several flights without the required certificates for commercial operations. The FAA suspended their Airline Transport Pilot (ATP) certificates for 270 days, alleging they operated the flights as air carriers or commercial operators without proper certification. The pilots received their regular salaries but no additional compensation for these flights.The FAA issued a Notice of Proposed Certificate Action, which the pilots appealed to the National Transportation Safety Board (NTSB). An administrative law judge (ALJ) upheld the FAA's suspension order, finding that the flights were conducted for compensation and hire, thus requiring compliance with Part 135 regulations. The NTSB affirmed the ALJ's decision, concluding that the flights were subject to air carrier or commercial operator requirements and that the pilots violated multiple FAA regulations. The NTSB also found that the ALJ did not exhibit bias and that the 270-day suspension was appropriate.The United States Court of Appeals for the First Circuit reviewed the case. The court held that substantial evidence supported the NTSB's findings that the flights were operated as common carriers for compensation, thus requiring Part 135 certification. The court also found that the pilots were responsible for ensuring compliance with FAA regulations, regardless of BAI's role in booking the flights. The court upheld the NTSB's decision, including the 270-day suspension of the pilots' certificates, finding it justified based on the pilots' regulatory violations and the potential risk to passenger safety. The petition for review was denied. View "Bonnet v. Whitaker" on Justia Law
MENDOCINO RAILWAY V. AINSWORTH
Mendocino Railway, a California corporation, owns and operates a railroad line known as the "Skunk Train" between Fort Bragg and Willits, California. The City of Fort Bragg and the California Coastal Commission sought to regulate the use and maintenance of the Railway's properties within the City, which the Railway resisted, claiming federal preemption under the Interstate Commerce Commission Termination Act (ICCTA). The City filed a state court action seeking declaratory and injunctive relief to compel the Railway to comply with local regulations. The Railway argued that federal law preempted these local regulations. Subsequently, the Railway filed a federal lawsuit seeking a declaration that the City's and Commission's regulatory actions were preempted by federal law and an injunction to prevent interference with its operations.The Mendocino County Superior Court overruled the Railway's demurrer, which argued that federal law preempted all local regulations. The Railway's subsequent petitions to the California Court of Appeal and the California Supreme Court were unsuccessful. The Railway then filed an answer in the state court, asserting federal preemption as an affirmative defense. Meanwhile, the Commission intervened in the state court action, seeking a declaration that the Coastal Act and local coastal program applied to the Railway's activities and were not preempted by federal law. The Railway also attempted to remove the state action to federal court, but the district court remanded it back to state court.The United States Court of Appeals for the Ninth Circuit reviewed the district court's dismissal of the Railway's federal lawsuit under the Colorado River doctrine, which allows federal courts to abstain from exercising jurisdiction in favor of parallel state court proceedings. The Ninth Circuit affirmed the district court's dismissal, finding that the state court proceedings were sufficiently parallel to the federal action and that considerations of avoiding piecemeal litigation, forum shopping, and the order in which the forums obtained jurisdiction supported the dismissal. The court held that the state court could adequately protect the Railway's rights and that the federal preemption issue could be resolved in the state court proceedings. View "MENDOCINO RAILWAY V. AINSWORTH" on Justia Law
Hardy v. Scandinavian Airline System
Susan Hardy, a resident of Louisiana, flew from Newark, New Jersey, to Oslo, Norway, on Scandinavian Airlines System (SAS). Upon disembarking in Oslo, she fell and fractured her leg. Hardy sued SAS in the Eastern District of Louisiana, claiming that Article 33 of the Montreal Convention provided both subject matter and personal jurisdiction over SAS. The district court dismissed her case, ruling that the Montreal Convention only granted subject matter jurisdiction and not personal jurisdiction. Additionally, the court found that SAS’s waiver of service did not establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2).The United States District Court for the Eastern District of Louisiana dismissed Hardy’s complaint without prejudice. The court concluded that Article 33 of the Montreal Convention did not create personal jurisdiction over SAS. It also rejected Hardy’s argument that SAS’s waiver of service under Federal Rule of Civil Procedure 4(k)(2) established personal jurisdiction, reasoning that SAS did not have sufficient contacts with Louisiana to warrant such jurisdiction.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Article 33 of the Montreal Convention does not independently create personal jurisdiction over a defendant airline, as it only prescribes venue. However, the court found that the district court erred in its analysis under Rule 4(k)(2). The correct analysis should have considered SAS’s contacts with the United States as a whole, not just Louisiana. The Fifth Circuit concluded that SAS had sufficient minimum contacts with the United States to establish personal jurisdiction under Rule 4(k)(2). Consequently, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "Hardy v. Scandinavian Airline System" on Justia Law
Union Pacific Railroad Co. v. STB
Union Pacific Railroad Company and the Association of American Railroads challenged the Surface Transportation Board's (Board) adoption of the Final Offer Rate Review (FORR) procedure for determining the reasonableness of rail carrier rates in smaller cases. Under FORR, the Board selects either the shipper’s or the rail carrier’s final offer without modification. The petitioners argued that the Board lacked statutory authority to implement FORR, that FORR was unconstitutionally vague, and that it was arbitrary and capricious.The Board is tasked with resolving rate disputes between rail carriers and shippers when rates are not set by private contract. The Board must hold a "full hearing" and give due consideration to specific statutory factors before determining the reasonableness of a rate. The Board adopted FORR to streamline the process for smaller disputes, allowing it to choose between the final offers submitted by the parties.The United States Court of Appeals for the Eighth Circuit reviewed whether the Board had statutory authority to implement FORR. The court concluded that FORR conflicted with the Board’s statutory duties. The court held that the Board must hold a "full hearing" and that the shipper must bear the burden of proof on the final offer, which FORR did not require. Additionally, the court found that FORR improperly limited the Board’s ability to prescribe the maximum rate, as required by statute, by forcing the Board to choose between the parties' final offers without modification.The Eighth Circuit granted the petitions for review and vacated the final rule, holding that the Board lacked statutory authority to implement FORR. View "Union Pacific Railroad Co. v. STB" on Justia Law
Bold v. Commonwealth
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