Justia Transportation Law Opinion Summaries

The First Circuit reversed the judgment of the district court dismissing for want of jurisdiction under the Tax Injunction Act (TIA) this lawsuit asking that the district court enjoin the collection of certain Rhode Island tolls as violative of the Commerce Clause of the United States Constitution, holding that the TIA's prohibition stating that district courts shall not enjoin levy or collection of "any tax under State law" where a remedy may be had in state courts is inapplicable to the Rhode Island tolls.A Rhode Island statute authorized the Rhode Island Department of Transportation to collect from tractor-trailers certain tolls in order to pay for replacement, reconstruction, maintenance, and operation of Rhode Island bridges. Plaintiff trucking entities brought this lawsuit. The district court dismissed the lawsuit, concluding that it lacked jurisdiction under the TIA. The First Circuit reversed, holding the the tolls in this case were not a "tax" under the statute. View "American Trucking Ass'n v. Alviti" on Justia Law

In this Title III adversary proceeding the First Circuit affirmed the judgment of the district court dismissing Ambac Assurance Corporation's constitutional and statutory challenges to measures the Commonwealth of Puerto Rico has taken to block payments to holders of Puerto Rico Highways and Transportation Authority (HTA) bonds, holding that the Title III court lacked the authority to grant the declaratory and injunctive relief that Ambac sought.Ambac, a financial guaranty insurer and individual holder of HTA bonds, commenced this adversary action in the so-called Title III court within the context of HTA's debt-adjustment proceedings pursuant to the Puerto Rico Oversight, Management, and Economic Stability Act. Ambac brought Contracts Clause, Takings Clause, Due Process Clause, preemption, and statutory challenges to the Commonwealth's actions and sought a negative injunction preventing the Commonwealth from continuing to impair the flow of HTA revenues to bondholders. The Title III court dismissed the complaint with prejudice. The First Circuit affirmed, holding that the Title III court was barred from granting Ambac declaratory or injunctive relief in this case. View "Ambac Assurance Corp. v. Commonwealth of Puerto Rico" on Justia Law

In this consolidated appeal from adversary proceedings challenging an alleged diversion of funds to which Peaje Investments LLC (Peaje) claimed it was entitled, the First Circuit held that Peaje did not hold a statutory lien on certain toll revenues of the Puerto Rico Highways and Transportation Authority (Authority).The Authority and the Commonwealth of Puerto Rico commenced bankruptcy cases under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act, 48 U.S.C. 2101-2241. Peaje, the beneficial owner of $65 million of uninsured bonds issued by the Authority, instituted adversary proceedings alleging that its bonds were secured by a lien on certain Authority toll revenues and that the Authority and the Commonwealth of Puerto Rico were diverting funds to which Peaje was entitled under the lien and using them for purposes other than paying the bonds. The First Circuit affirmed the Title III court’s primary grounds for its order denying Peaje’s request for a preliminary injunction and relief from the stay and otherwise vacated and remanded the matter, holding (1) Peaje did not hold a statutory lien on Authority toll revenues; and (2) now that it is clear that Peaje has no statutory lien, the district court’s alternative reasons for denying relief should be reconsidered de novo on an updated record. View "Peaje Investments LLC v. Puerto Rico Highways & Transportation Authority" on Justia Law

In this action brought under the Interstate Commerce Commission Termination Act (ICCTA) the First Circuit denied the petition for review filed by Petitioners, holding that the Surface Transportation Board (STB) did not err by concluding that certain activities at a Grafton & Upton Railroad Company (G&U) facility involving wood pellets qualified as “transportation by rail carrier” and so fell within the exclusive jurisdiction of the STB.The Upton, Massachusetts board of selectmen concluded that the ICCTA preempted local regulation of the wood-pellet activities at G&U’s local facility. Petitioners, who lived near the facility, asked the STB for a declaratory order that these activities were not part of “transportation by rail carrier” under ICCTA because they were manufacturing activities, and therefore, there could be no federal preemption of otherwise-applicable state and local regulations. The STB concluded that the complained-about activities qualified as “transportation” under the ICCTA and therefore fell within the STB’s jurisdiction. The First Circuit denied Petitioners’ petition for review, holding that Petitioners failed to show that the STB acted arbitrarily or capriciously, abused its discretion, or otherwise violated the law. View "Del Grosso v. Surface Transportation Board" on Justia Law