Justia Transportation Law Opinion Summaries

Plaintiffs filed suit under 42 U.S.C. 1983 and state civil rights law, contending that the impoundment of their vehicles by local authorities based on plaintiffs' lack of a driver's license violated the Fourth Amendment. California Vehicle Code 4602.6(a)(1) provides that a peace officer may impound a vehicle for 30 days if the vehicle’s driver has never been issued a driver's license.Applying Brewster v. Beck, 859 F.3d 1194, 1196–97 (9th Cir. 2017), the panel held that 30-day impounds under section 14602.6 are seizures for Fourth Amendment purposes. Therefore, the only issue in this case was whether the impounds were reasonable under the Fourth Amendment. The panel held that, although the state's interest in keeping unlicensed drivers off the road is governed by the community caretaking exception of the Fourth Amendment, the exception does not categorically permit government officials to impound private property simply because state law does. Furthermore, even if the panel were to balance the state's interest against the driver's interests, the County would still be wrong to rely on a deterrence or administrative penalty rationale to support California's interests. Therefore, the panel affirmed the district court's grant of summary judgment for plaintiffs on the Fourth Amendment claims.The panel affirmed the district court's grant of summary judgment on plaintiffs claim that the County and the City were liable for money damages as final policymakers who caused the constitutional violations; affirmed the denial of class certification for lack of commonality and typicality; and affirmed summary judgment for defendants on the California Bane Act claim. View "Sandoval v. County of Sonoma" on Justia Law

After a jury found that BNSF violated the anti-retaliation provision of the Federal Railroad Safety Act (FRSA) when it fired plaintiff for, in part, refusing to stop performing an air-brake test on a 42-car train that he was tasked with moving, plaintiff was awarded over $1.2 million in damages.The Ninth Circuit held that the district court did not err in denying BNSF's motion for judgment as a matter of law with respect to whether plaintiff engaged in FRSA-protected activity. Therefore, the panel affirmed the district court's grant of judgment as a matter of law on that claim. However, the panel reversed the district court's grant of summary judgment to plaintiff on the contributing-factor issue because the district court conflated plaintiff's prima facie showing, which he successfully made as a matter of law, with his substantive case, which should have gone to the jury. The panel held that plaintiff was entitled to summary judgment on the contributing-factor element of his prima facie showing, but that he was not entitled to summary judgment on his substantive case. View "Rookaird v. BNSF Railway Co." on Justia Law

The Ninth Circuit affirmed the district court's preliminary injunction preventing implementation of California Senate Bill 84, which requires railroads to collect fees from customers shipping certain hazardous materials and then to remit those fees to California. The district court held that the railroads were likely to succeed on the merits of their claims. The panel agreed and held that SB 84 was preempted under the Interstate Commerce Commission Termination Act because it had a direct effect on rail transportation, and it was not protected from preemption by the Hazardous Materials Transportation Uniform Safety Act because the fees authorized by SB 84 were not "fair." The panel also held that the district court did not abuse its discretion in evaluating irreparable harm, the balance of the equities, and the public interest. View "BNSF Railway Co. v. California Department of Tax and Fee Administration" on Justia Law

The Ninth Circuit affirmed the district court's dismissal of an action brought by for-hire drivers challenging a Seattle ordinance that establishes a multistep collective bargaining process between "driver-coordinators," such as Uber and Lyft, and for-hire drivers who contract with those companies. The panel held that the drivers' claims under the National Labor Relations Act were unripe because they failed to allege an injury in fact that was concrete and particularized. In this case, even assuming arguendo that the disclosure of drivers' personal information to the union under the ordinance was imminent, the disclosure was neither a concrete nor a particularized injury. Furthermore, no contract or agreement was imminent. The court also held that the drivers' First Amendment claims were unripe for the same reasons. View "Clark v. City of Seattle" on Justia Law

The en banc court held that the Railway Labor Act did not preempt a worker's claim premised on a state law right to reschedule vacation leave for family medical purposes, when the worker's underlying right to vacation leave was covered by a collective bargaining agreement (CBA). The court also held that the Act did not preempt the worker's claim because the claim neither arose entirely from nor required construction of the CBA. Furthermore, that the CBA must be consulted to confirm the existence of accrued vacation days was not sufficient to extinguish the worker's independent state law right to use the accrued time to care for a sick child. Accordingly, the court affirmed the district court's grant of summary judgment to defendants. View "Alaska Airlines v. Schurke" on Justia Law

The Ninth Circuit reversed the district court's order granting a motion to dismiss Union Pacific's counterclaims in class actions filed by landowners challenging the railroad's ability to lease land to Santa Fe Pacific Pipelines (SFPP). The panel rejected plaintiffs' contention that the panel should not reach the merits of the certified questions and declined to apply the doctrine of collateral estoppel. With respect to the first certified question, the panel held that the pre-1871 Acts, which Congress passed to aid in the construction of railroad lines, do not require a "railroad purpose." In regard to the second certified question, the panel held that Union Pacific has plausibly alleged that the pipeline serves such a purpose. Therefore, the court remanded with instructions to grant leave to amend. View "Wells v. Union Pacific Railroad Co." on Justia Law

The Ninth Circuit denied petitions for review of the FMCSA's statutory authority to issue permits for U.S. long-haul operations to Mexico-domiciled trucking companies. The panel held that the Teamsters and the Drivers Association have constitutional standing; the U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act of 2007 encompasses the Teamsters' and the Drivers Association's claims; and the Teamsters and the Drivers Association also have third-party organizational standing. The panel also held that the grant of a long-haul operating permit to a Mexico-domiciled carrier and the denial of the Teamsters' challenge to that grant were final agency actions; the panel has Hobbs Act jurisdiction over the petition for review of the decision to grant Trajosa a permit; whether to grant long-haul authority based on the results of the pilot program was "committed to agency discretion by law" and was thus unreviewable; and therefore the panel may not review the FMCSA's decision to grant Trajosa an operating permit. View "International Brotherhood of Teamsters v. USDOT" on Justia Law