Justia Transportation Law Opinion Summaries

In this case, the plaintiff, Anila Daulatzai, was removed from a Southwest Airlines flight after the captain received information about her dog allergy and the presence of two dogs on board. Daulatzai insisted on remaining in her seat despite the captain’s decision, leading to her physical removal by Maryland Transportation Authority police officers. She was later charged with various offenses, including disorderly conduct and resisting arrest.Daulatzai filed an action against Southwest Airlines and the State of Maryland, alleging various grounds to challenge her removal from the plane and her arrest. The district court dismissed Daulatzai’s complaint for failure to state a plausible claim upon which relief could be granted. Daulatzai appealed that judgment and, while her appeal was pending, she also filed a motion in the district court under Federal Rule of Civil Procedure 60(b), seeking to file a fourth version of her complaint with the district court.The court denied her request, finding that her efforts were pursued in bad faith, that her repeated failures to cure defects in her pleadings had been prejudicial to the defendants, and that the fourth complaint would, in any event, be futile. Daulatzai appealed that ruling as well.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding that Daulatzai had failed to establish any of the grounds for relief under Rule 60(b) and that the district court did not abuse its discretion in denying Daulatzai leave to file her proposed third amended complaint. The court also found that Daulatzai had waived her challenge to the district court’s dismissal of her second amended complaint by failing to preserve it below. View "Daulatzai v. Maryland" on Justia Law

Plaintiff, an African American woman, worked as a conductor for Amtrak National Railroad Passenger Corporation (Amtrak). During her employment, she belonged to a division of the Sheet Metal, Air, Rail and Transportation Workers (SMART) union, which maintained a collective bargaining agreement (CBA) with Amtrak. Plaintiff brought the instant lawsuit pro se. She named Amtrak and the company’s director of employee relations as Defendants, along with three other Amtrak colleagues. Plaintiff asserted state-law claims of breach of contract and tort, as well as a federal claim of racial discrimination in violation of Title VII. Defendants moved to dismiss, and Plaintiff moved for summary judgment as well as for leave to amend her complaint. The district court granted Defendants’ motion and denied Plaintiff’s two motions. The district court held that Plaintiff’s claims were subject to arbitration under the Railway Labor Act (RLA).   The Fourth Circuit affirmed. The court explained that it declines to unwind a statutory scheme without a clear congressional directive to do so. Plaintiff argued that at least her particular claim is not a minor dispute. The mere fact that Plaintiff’s claim arises under Title VII does not disqualify that claim from being a minor dispute within the RLA’s ambit. The thrust of Plaintiff’s Title VII claim is that Amtrak deviated from its policies when dealing with her. While Plaintiff’s allegations as to her own treatment are factual, those concerning Amtrak’s policies directly implicate the relevant CBA between Plaintiff’s union, SMART, and Amtrak. That some of Plaintiff’s interpretive disagreements concern the Drug-Free Program does not alter the character of her claim. View "Dawn Polk v. Amtrak National Railroad Passenger Corporation" on Justia Law

Plaintiff appealed the district court’s dismissal of her putative class action against the West Virginia Parkways Authority, in which she alleges that the Parkways Authority improperly collected fees. And the Parkways Authority appeals the district court’s holding that it was not entitled to sovereign immunity under the United States or West Virginia Constitutions.   Plaintiff relied on the Class Action Fairness Act for jurisdiction. The Fourth Circuit vacated the district court’s judgment and remanded the case remanded to the district court with directions to dismiss without prejudice. The court concluded that here, Section 1332(d)(5)(A) bars jurisdiction under Section 1332(d)(2) of the Class Action Fairness Act. The court explained that the Parkways Authority is the only, and thus “primary,” defendant. And it is a “governmental entity.” The Parkways Authority’s sovereign-immunity claim is strong enough to conclude that the district court “may be foreclosed from ordering relief” against it. So Section 1332(d)(2)’s jurisdictional grant “shall not apply.” Since that is the only provision that Plaintiff relies on to establish jurisdiction over her putative class action, the district court lacked jurisdiction to hear it. View "Blazine Monaco v. WV Parkways Authority" 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

Skidmore’s West Virginia home sits 70-80 feet west of Norfolk’s railroad track, across Loop Creek. In 2001, Norfolk installed a culvert to drain surface water from its tracks into Loop Creek near Skidmore’s home. According to Skidmore, the water streaming from the culvert caused soil erosion and threatened the foundation of her home. Skidmore sued Norfolk in state court, alleging negligence, private nuisance, and trespass.Norfolk obtained a survey and deeds revealing that, in 1903, Norfolk obtained a right of way extending across Loop Creek, over part of the land on the other side. Part of Skidmore’s house sits atop the land over which the right of way runs. Norfolk asserted an affirmative defense that Skidmore lacked standing because she had no right to exclude Norfolk from the land. Skidmore amended her complaint to add claims for adverse possession and prescriptive easement (quiet title claims). Norfolk removed the case to federal court, arguing that the Interstate Commerce Commission Termination Act completely preempts the quiet title claims. The district court dismissed for lack of subject matter jurisdiction.The Fourth Circuit vacated. While 49 U.S.C. 10501(b) “entirely displaces” Skidmore’s quiet title claims, a conclusion that complete preemption applies means that the court has jurisdiction over ostensibly state-law claims. On remand, the court must convert Skidmore’s quiet title claims into claims under the Termination Act and may permit Skidmore to amend her complaint to clarify the scope of her Termination Act claims. View "Skidmore v. Norfolk Southern Railway Co" on Justia Law

The Fourth Circuit affirmed the district court's order granting summary judgment to the City and the Foundation in an action alleging discriminatory taxation in violation of the Railroad Revitalization and Regulatory Reform Act of 1976. The court applied the factors in San Juan Cellular Tel. Co. v. Pub. Serv. Comm'n, 967 F.2d 683, 685 (1st Cir. 1992), and held that the City's storm water management charge was a fee, rather than a tax, and therefore was not subject to the Act's requirements. In this case, the charge was imposed by the City's legislative body, and the charge was part of a comprehensive regulatory scheme. View "Norfolk Southern Railway Co. v. City of Roanoke" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of plaintiffs' constitutional and statutory challenges to Metropolitan Washington Airport Authority's (MWAA) ability to use toll revenues to fund projects enhancing access to Dulles airport. The court applied the standard from Lebron v. National Railroad Passenger Corporation, 513 U.S. 374 (1995), and held that MWAA was not a federal entity. The court held that MWAA's structure did not violate the non-delegation principle because MWAA exercises no power assigned elsewhere by the Constitution; MWAA did not violate the Guarantee Clause because it did not deny any state a republican form of government; and the court rejected plaintiff's claim that MWAA's use of toll road funds to build metro service to Dulles violates the command that funds only be spent on "capital and operating costs of the Metropolitan Washington Airports" and agreed with the Secretary of Transportation's interpretation of the Lease and Transfer Act. View "Kerpen v. Metropolitan Washington Airports Authority" on Justia Law