Justia Transportation Law Opinion Summaries

Petitioners, the Owner-Operator Independent Drivers Association and one of its members, seek review of regulatory guidance issued by the FMCSA, which exempts from federal accident-reporting regulations certain accidents involving commercial motor vehicles known as attenuator trucks. The court dismissed the petition for lack of an Article III case or controversy because petitioners have failed to identify a concrete and particularized injury that would give them standing to proceed. View "OOIDA v. US Dep't of Transp." on Justia Law

Plaintiff filed suit alleging that Central Transport violated the overtime requirements of the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), when it employed him as a "switcher" at its St. Louis terminal. The district court granted summary judgment to Central Transport. The FLSA exempts “any employee with respect to whom the Secretary of Transportation has power to establish qualifications and maximum hours of service” under the Motor Carrier Act (MCA), 29 U.S.C. 213(b)(1). Based on the Supreme Court’s controlling precedents, the court concluded that, if an employee spends a substantial part of his time participating in or directing the actual loading of a motor vehicle common carrier’s trailers operating in interstate or foreign commerce, the Secretary of Transportation has the authority to regulate that employee’s hours of service and the MCA Exemption applies, regardless of the employee’s precise role in the loading process. Because the summary judgment record conclusively establishes that a substantial part of plaintiff's time during the relevant period was spent loading Central Transport trailers for interstate transportation, the MCA Exemption applies in this case. Accordingly, the court affirmed the judgment. View "Williams v. Central Transport Int'l" on Justia Law

Plaintiff filed suit against various municipalities and their employees under the Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2721-25, after municipal and state personnel had accessed plaintiff’s personal information approximately sixty times between 2003 and 2012. The district court dismissed plaintiff's claims without prejudice but allowed her to file an amended complaint. Plaintiff instead requested that the district court enter final judgment dismissing her case with prejudice. Then plaintiff appealed the district court’s decision without receiving the judgment she requested. The court concluded that, because plaintiff did not obtain a final judgment following the district court’s dismissal of her complaint with leave to amend, the court lacked jurisdiction over the appeal. Accordingly, the court dismissed the appeal. View "Sapp v. City of Brooklyn Park" on Justia Law

BN applied for an exemption permitting expeditious abandonment of a railroad line. The STB granted but then revoked an exemption prior to completion of the abandonment and instead authorized BN to enter into an “interim trail use/rail banking agreement” in accordance with the National Trails System Act (Trails Act), 16 U.S.C. 1247(d), as implemented by the STB in 49 C.F.R. 1152.29. In 2014, plaintiffs, ranchers who own properties underlying and surrounding the railway right-of-way easement, filed two separate actions against the State and the Department, seeking a declaration quieting title to the right-of-way because the easement terminated by operation of law when BN ceased railroad operations. The district court consolidated the two cases and concluded that plaintiffs' claims fall within the exclusive jurisdiction of the STB, and granted Fed. R. Civ. P. 12(b)(1) dismissals for lack of subject matter jurisdiction. The court concluded that plaintiffs' claims are not within the STB’s exclusive jurisdiction, but that the Amended Complaints - alleging that defendants “stand in the shoes” of the BN, and therefore defendants cannot impose non-railroad restrictions on plaintiffs’ rights as servient landowners,- failed to state a claim upon which relief can be granted. Accordingly, the court modified part of the district court judgment and otherwise affirmed. View "Trevarton v. South Dakota" on Justia Law

Petitioners filed suit against BNSF and its contractor, Massman, alleging that the loss they suffered when their family farm was flooded was caused by BNSF's maintenance of a railway embankment running across their farm. The Board concluded that the Interstate Commerce Commission Termination Act (ICCTA), 49 U.S.C. 10501(b), preempted petitioners' state law claims but that they retained a federal claim based on BNSF's alleged violation of federal regulations. The court concluded that petitioner failed to properly challenge the Board's use of the unreasonable-burden-or-interference test for as-applied preemption. Therefore, the court declined to overturn the Board's use of the test. The court also concluded that petitioners' state law claims unreasonably burden or interfere with rail transportation and the Board's determination is supported by substantial evidence. Accordingly, the court denied the petition for review. View "Tubbs v. STB" on Justia Law

Mechanics, members of the Union and employees of Metro, filed a declaratory judgment action, seeking a declaration under section 13(c) of the Urban Mass Transportation Act of 1964 (UMTA), 49 U.S.C. 5333, that Metro must establish a framework through which they could form a bargaining unit separate from the Union. The Union intervened and the district court granted the Union's motion to dismiss for failure to state a claim. The court concluded that the district court correctly determined that section 13(c) does not entitle mechanics to the relief they seek because Congress did not intend to provide a federal forum for disputes between unions and transit authorities; the language and structure of section 13(c) does not suggest that Congress intended to create a federal private cause of action; and the consistent theme in Section 13(c)’s legislative history was that “Congress intended that labor relations between transit workers and local governments would be controlled by state law[.]" Accordingly, the court affirmed the judgment. View "Stenger v. Bi-State Dev. Agency" on Justia Law