Justia Transportation Law Opinion Summaries

James Hamre died when an Amtrak train derailed in Dupont, Washington, in 2017. He was survived by his mother, who lived with him, and three adult siblings. Under the wrongful death statutes in effect at the time, James’ mother could recover for his wrongful death because she was dependent on him, while his siblings could recover nothing because they did not rely on James financially. The wrongful death beneficiary statute in effect at that time also denied any recovery to beneficiaries like parents or siblings if they did not reside in the United States. In 2018, one of James’ brothers, acting as his personal representative, agreed to a settlement and release with the National Railroad Passenger Corporation (aka Amtrak), on behalf of their mother, the only then qualifying wrongful death beneficiary. In 2019, the Washington Legislature amended RCW 4.20.020 to remove the requirement that second tier beneficiaries (parents and siblings) be both dependent on the decedent and residents of the United States. It explicitly stated that the amendment should apply retroactively to claims that were not time barred. In 2020, James’ siblings who qualified as beneficiaries under the revised statute brought wrongful death actions against Amtrak. Amtrak argued that retroactive application would violate its contracts clause and due process rights under the Washington Constitution. The federal district court certified two questions to the Washington Supreme Court to address the issue of retroactivity, and the Supreme Court concluded the Washington State Legislature intended the 2019 amendments to RCW 4.20.020 to apply retroactively to permit newly qualified second tier beneficiaries to assert wrongful death claims that were not time barred. View "Kellogg v. Nat'l R.R. Passenger Corp." on Justia Law

Enacted after the Exxon Valdez oil spill, the Oil Pollution Act of 1990 (OPA), creates a comprehensive remedial scheme that governs—and apportions liability for—oil-removal costs. OPA holds oil spillers strictly liable upfront for oil-removal expenses and allows them, if they meet certain requirements, to avail themselves of one of three liability defenses and to seek contribution from other culpable parties. The M/V SAVAGE VOYAGER was transporting oil through a Mississippi waterway when an accident at a boat lift— operated by the U.S. Army Corps of Engineers—caused a rupture in the SAVAGE VOYAGER’s hull, through which thousands of gallons of oil poured into the river.The owners of the vessel sued the United States, not under the OPA, but under the common-law admiralty regime. They cited the Suits in Admiralty Act (SAA), a 1920 law by which Congress generally waived sovereign immunity for most admiralty claims. The interplay between the OPA and the SAA was an issue of first impression in the federal courts. The Eleventh Circuit affirmed the dismissal of the vessel owner’s claims for removal costs. OPA authorizes no claim against the government for oil-removal damages and OPA’s comprehensive remedial scheme displaced the SAA’s more general sovereign-immunity waiver. View "Savage Services Corp. v. United States" on Justia Law

Plaintiffs purchased tickets for Defendant’s commercial flights from Miami to Venezuela. Plaintiffs allege that their ticket prices reflected the “fully-paid contract” and that Defendant failed to sufficiently disclose any other fees required for passage. When checking in for their flights at the airport, however, Defendant informed Plaintiffs that they had to pay an additional $80 “Exit Fee” before being allowed to board their flights. Plaintiffs filed a breach of contract putative class action.The district court dismissed the suit, concluding that the Airline Deregulation Act preempted Plaintiffs’ breach of contract claim because it related to the price of the airline ticket and the Act’s preemption provision identifies actions relating to price as preempted. The Eleventh Circuit reversed, first holding that the Plaintiffs plausibly alleged facts that would establish diversity jurisdiction. Plaintiffs’ breach of contract claim seeks merely to enforce the parties’ private agreements regarding the cost of passage and does not invoke state laws or regulations to alter the agreed-upon price. The statute, 49 U.S.C. 41713(b)(1), provides: “[A] State . . . may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of an air carrier..” The suit falls within the category of cases protected from preemption by Supreme Court precedent. View "Cavalieri v. Avior Airlines C.A." on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court denying the motion to compel arbitration brought by Uber Technologies, Inc. and Rasier, LLC (collectively, Uber) in this action brought by Patricia Sarchi, a user of Uber's ride-sharing service, and the Maine Human Rights Commission, holding that the superior court did not err.Plaintiffs brought this action against Uber for violating the Maine Human Rights Act, Me. Rev. Stat. 5, 4592(8), 4633(2), after Sarchi, who was blind, was refused a ride because of her guide dog. Uber moved to compel Sarchi to arbitrate and to dismiss or stay the action pending arbitration. The motion court denied the motion to compel, concluding that Sarchi did not become bound by the terms and conditions of Uber's user agreement. The Supreme Judicial Court affirmed, holding that, under the facts and circumstances of this case, Sarchi was not bound by the terms. View "Sarchi v. Uber Technologies, Inc." on Justia Law

Coffey was employed by the Railway as a locomotive engineer. In 2012, a train that Coffey was operating derailed; a drug test revealed the presence of amphetamines in Coffey’s system. Coffey was permitted to continue working, but he was subject to follow-up drug testing for five years. In 2016, a test showed the presence of amphetamines and codeine. Coffey explained that he had prescriptions for Adderall, which he took for ADHD, and codeine (Tylenol #3), which he took for a back condition. Railway requested that Coffey provide medical records. Six weeks later, Coffey ruptured his Achilles tendon and took medical leave for 10 months. When his physician cleared him to return to work, Railway again requested the records it had previously requested. After two more demands, Railway received some records but was unsatisfied because they failed to include specifically requested information such as medication side effects. In anticipation of a disciplinary hearing, Coffey submitted approximately 400 pages of medical records. Upon determining that those records still did not address much of the required information, Railway terminated Coffey’s employment.The EEOC concluded that there was reasonable cause to believe that Railway’s demands violated the ADA, 42 U.S.C. 12112(a). The district court and Fourth Circuit rejected Coffey’s subsequent suit. Railway made a lawful request under the ADA. Its inquiries were related to Coffey’s job and were required by federal regulation. Complying with federal regulations is, by definition, a business necessity. View "Coffey v. Norfolk Southern Railway Co." on Justia Law

Municipal authorities in Oklahoma fined Plaintiff BNSF Railway Company for violating its Blocked Crossing Statute—setting up a preemption challenge between the federal Interstate Commerce Commission Termination Act (“ICCTA”) and the Blocked Crossing Statute. Defendants argued the Federal Railroad Safety Act (“FRSA”), not the ICCTA, applied to Oklahoma’s statute and did not preempt it. The district court held that the ICCTA preempted Oklahoma’s Blocked Crossing Statute because it regulated railroad operations. The Tenth Circuit agreed with the federal district court and affirmed its decision. View "BNSF Railway v. City of Edmond, et al." on Justia Law

The First Circuit affirmed in part and vacated in part the holdings of the district court affirming the conclusions of the Federal Highway Administration (FHWA) approving the Maine Department of Transportation's (MDOT) plan to construct a modern bridge upstream of a current, historic bridge and to tear down the historic bridge when construction is finished, holding that the agency's decision was not arbitrary or capricious.Plaintiffs brought this action challenging the FHWA's decision to approve Maine's decision, seeking to review and set aside that approval. The district court considered and rejected several of Plaintiffs' arguments. The First Circuit affirmed all of the district court's holdings except one, holding (1) Plaintiffs' challenges to the cost estimates were without merit; and (2) the matter must be remanded to the FHWA for the limited purpose of allowing the agency to justify use of a service-life analysis. View "Historic Bridge Foundation v. Buttigieg" on Justia Law

Appellants, two individuals who have traveled on Amtrak in connection with their work and expect to continue doing so, sought declaratory and injunctive relief to prevent Amtrak from imposing an arbitration requirement on rail passengers and purchasers of rail tickets.The DC Circuit affirmed the district court's dismissal of the complaint because appellants have not plausibly alleged an actual injury-in-fact and therefore lack Article III standing. In this case, appellants have alleged neither ongoing nor imminent future injury. Rather, appellants assert only one cognizable interest, the interest in purchasing tickets to travel by rail, but Amtrak's new term of service has not meaningfully abridged that interest. View "Weissman v. National Railroad Passenger Corp." on Justia Law

Petitioner sought review of the TSA's Mask Directives, issued in response to the ongoing COVID-19 pandemic, claiming that the TSA has no authority to issue the directives. Petitioner argued that TSA's authority under the Aviation and Transportation Security Act does not empower TSA to require face masks to prevent the spread of COVID-19.The DC Circuit found no merit in petitioner's claim and denied the petition for review. The court concluded that the COVID-19 global pandemic poses one of the greatest threats to the operational viability of the transportation system and the lives of those on it seen in decades. TSA, which is tasked with maintaining transportation safety and security, plainly has the authority to address such threats under both sections 114(f) and (g) of the Aviation and Transportation Security Act. The court stated that the Mask Directives are reasonable and permissible regulations adopted by TSA to promote safety and security in the transportation system against threats posed by COVID-19. The Mask Directives are not ultra vires, and the court deferred to the agency's interpretation of the Act. View "Corbett v. Transportation Security Administration" on Justia Law

Belt Railway, the largest switching and terminal railroad in the U.S., has more than 250 miles of track in its main yard south of Chicago’s Midway Airport. Jointly owned by six railroads—BNSF, Canadian National, Canadian Pacific, CSX, Norfolk Southern, and Union Pacific—Belt dispatches more than 8,000 cars a day. Wisconsin Central (a Canadian National subsidiary) prefers to receive Soo Line (a Canadian Pacific subsidiary) traffic at Belt’s yard; Soo prefers the Spaulding yard, 25 miles to the west. The Surface Transportation Board ruled that Wisconsin Central cannot insist that Soo deliver to Belt because a carrier’s power to designate a place where it will receive traffic is limited to line that the designating carrier owns; Wisconsin Central does not wholly own Belt.The Seventh Circuit vacated. “A rail carrier ... shall provide reasonable, proper, and equal facilities that are within its power to provide for the interchange of traffic between … its respective line and a connecting line of another rail carrier, 49 U.S.C. 10742. The Board improperly read “that are within its power to provide” as “that it owns.” A rail carrier can have the “power to provide” facilities by ownership or under a contract. The Board also erred in assuming that the statute requires the two railroads have physically intersecting lines and in making an assumption about expenses. The word “reasonable” gives the Board interpretive leeway; the phrase “that are within its power to provide” does not. View "Wisconsin Central Ltd. v. Surface Transportation Board" on Justia Law