Justia Transportation Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court affirming an order entered by the Office of Administrative Hearings (OAH) reinstating Respondent's personal driver's license and commercial driver's license after Defendant challenged the finding of the West Virginia Division of Motor Vehicles (DMV) that Respondent drove under the influence of alcohol, holding that there was no error.In 2017, the DMV revoked Respondent's personal driver's license and disqualified him from holding a commercial driver's license. Following an administrative hearing in 2019, the OAH rescinded the DMV's revocation and disqualification orders. The OAH reinstated both of Respondent's licenses, finding that the DMV had not proven that Respondent drove a motor vehicle while under the influence of alcohol. The circuit court affirmed. The Supreme Court affirmed, holding that the DMV did not establish by a preponderance of the evidence that Respondent drove a motor vehicle while he was under the influence of alcohol. View "Frazier v. Gaither" on Justia Law

The Court of Appeals held that warrantless inspections authorized by New York regulations adopting a rule promulgated by the Federal Motor Carrier Safety Administration (FMCSA) requiring the installation of electronic logging devices (ELD) in commercial motor vehicles fell within the administrative search exception to the warrant requirement.The FMCSA promgulated the rules at issue in 2015, and the rules were permanently incorporated into New York law in 2019. Petitioner commenced this combined N.Y. C.P.L.R. 78 proceeding and declaratory judgment action challenging New York's adoption of the rule. Supreme Court granted Respondents' motion to dismiss, concluding that the searches authorized by the rule were valid under the exception to the warrant requirement for administrative searches. The appellate division affirmed. The Court of Appeals affirmed as modified, holding (1) the lower courts properly determined that the ELD rule is constitutional; but (2) Supreme Court should have declared the rights of the parties rather than dismissing the complaint. View "Owner Operator Independent Drivers Ass'n v. N.Y. State Dep't of Transportation" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying three plaintiffs' motion for summary judgment in this suit brought to challenge the City of Des Moines' use of the state's income offset program to collect automated traffic citation penalties and granting summary judgment in favor of the City, holding that the district court erred in granting summary judgment as to a preemption claim and a claim for unjust enrichment.Specifically, the Supreme Court held that the district court properly dismissed Plaintiffs' claims that, among other things, the City's use of the income offset program amounted to an unconstitutional taking and that their right to procedural due process was violated. As to Plaintiffs' contention that the City's use of the program was preempted by state law, however, the district court reversed in part, holding that the district court erred in dismissing one plaintiff's preemption claim with respect to his requests for declaratory and injunctive relief and in dismissing two plaintiffs' claim for unjust enrichment. The Court remanded this case for further proceedings. View "Livingood v. City of Des Moines" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiffs' lawsuit challenging the City of Windsor Heights's attempts to collect automated traffic citation fines not reduced to a judgment in a municipal infraction proceeding, holding that the district court erred in part.At issue was an income offset program authorized pursuant to Iowa Code 8A.504 allowing the department of administrative services to "establish a debt collection setoff procedure for collection of debts owed to the public agency." Plaintiffs brought this action against the City and the City's collection agent challenging the program to enforce civil penalties issued pursuant to the automated traffic enforcement system. The district court dismissed all claims. The Supreme Court reversed in part and remanded the case for further proceedings, holding that the district court erred in dismissing some claims against the City as time-barred. View "Stogdill v. City of Windsor Heights" on Justia Law

In this case considering whether an easement (2018 easement) taken by eminent domain by the Department of Transportation (MassDOT) exceeded the scope of an easement taken in 1991 by the Department of Public Works (DPW), MassDOT's predecessor in interest, with respect to Plaintiff's land in South Boston (burdened land), the Supreme Judicial Court held that summary judgment was improperly granted for MassDOT.DPW's 1991 order of taking created an easement over the burdened land for purposes of constructing a haul road. In 2017, the Massachusetts Bay Transportation Authority began planning the construction of a test track on a portion of Plaintiff's land burdened by the 1991 easement. MassDOT recorded the 2018 confirmatory order of taking and then, contending that the taking merely confirmed that rights it held under the 1991 taking, refused to pay Plaintiff any compensation. Plaintiff responded with this litigation, and the superior court judge entered summary judgment in favor of MassDOT. The Supreme Judicial Court reversed, holding (1) while the intent of the parties should not be considered when an easement is taken by eminent domain, the ordinary rules of interpretation for easements otherwise apply; and (2) because the 1991 easement was more limited in scope than the 2018 easement, summary judgment for MassDOT must be reversed. View "Smiley First, LLC v. Dep't of Transportation" on Justia Law

Plaintiff was cited for misuse of a vehicle horn under Section 27001 after she honked in support of protestors gathered outside a government official’s office. Although the citation was dismissed, Plaintiff filed suit to block future enforcement of 27001 against any expressive horn use―including honks not only to “support candidates or causes” but also to “greet friends or neighbors, summon children or co-workers, or celebrate weddings or victories.” She asserted that Section 27001 violates the First and Fourteenth Amendments as a content-based regulation that is not narrowly tailored to further a compelling government interest. Alternatively, she argued that even if the law is not content-based, it burdens substantially more speech than necessary to protect legitimate government interests.   The Ninth Circuit affirmed the district court’s summary judgment in favor of the State of California. The first held that Plaintiff had standing to challenge the law because, ever since she received a citation for impermissible horn use, she has refrained from honking in support of political protests to avoid being cited again. The panel determined that, at least in some circumstances, a honk can carry a message that is intended to be communicative and that, in context, would reasonably be understood by the listener to be communicative. The panel noted that Plaintiff had not alleged that the State has a policy or practice of improper selective enforcement of Section 27001, so the panel had no occasion to address that possibility here. View "SUSAN PORTER V. KELLY MARTINEZ, ET AL" on Justia Law

The Jackson-Medgar Wiley Evers International Airport is a major airport located in Jackson, Mississippi. Since 1960, the airport has been operated by the Jackson Municipal Airport Authority, whose five commissioners are selected by the city government. In 2016, the Mississippi legislature passed, and the governor signed into law SB 2162, which abolishes the Jackson Municipal Airport Authority and replaces it with a regional authority composed of nine commissioners, only two of whom are selected by Jackson city government.   A Jackson citizen filed a suit seeking to enjoin the law. The mayor, the city council, the Jackson Municipal Airport Authority, its board of commissioners, and the commissioners in their individual capacities intervened in that lawsuit. The intervenors contend that SB 2162 violates the Equal Protection rights of the citizens of Jackson by eliminating the locally controlled Jackson Municipal Airport Authority for racially discriminatory reasons. The intervenors served subpoenas on eight nonparty state legislators who participated in SB 2162’s drafting and passage. The Legislators refused to comply with Request #3 in the subpoena, which sought documents and communications related to SB 2162, asserting that any responsive discovery would either be irrelevant or protected by legislative privilege. The magistrate judge, and later the district court, rejected this position.   The Fifth Circuit affirmed in part, reversed in part, and remanded. The court held that the district court did not abuse its discretion in ordering the Legislators to produce a privilege log. But the district court erred in broadly holding that legislative privilege was automatically waived for any documents that have been shared with third parties. View "Jackson Muni Airport v. Harkins" on Justia Law

The Court of Appeals affirmed the judgment of the Appellate Division dismissing Plaintiffs' claims that Taxi and Limousine Commission and New York City breached the implied covenant of good faith and fair dealing and engaged in deceptive business practices under N.Y. Gen. Bus. Law 349, holding that Plaintiffs failed to state a claim.Plaintiffs, entities that purchased government licenses to operate taxis at an auction, brought this action alleging that Defendants (1) breached the implied covenant of good faith and fair dealing by failing to enforce certain licensing requirements against smartphone applicate-based competitors such as Uber Technologies, Inc. and Lyft, Inc.; and (2) engaged in deceptive business practices in their promotion of the auction. Supreme Court granted in part Defendants' motion to dismiss. The Appellate Division reversed in part and concluded that both claims should be dismissed. The Court of Appeals affirmed, holding (1) Plaintiffs did not adequately plead a claim for breach of the implied covenant of good faith and fair dealing; and (2) Plaintiffs failed to plead the type of conduct covered by N.Y. Gen. Bus. Law 349. View "Singh v. City of New York" 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

The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the trial court in favor of Plaintiff in this negligence action, holding that the appellate court properly concluded that the "highway defect statute," Conn. Gen. Stat. 13a-149, was Plaintiff's exclusive remedy.Plaintiff was traveling behind a snowplow when the snowplow hit a manhole cover and knocked it off. Plaintiff's vehicle fell into the open manhole, rendering his vehicle inoperable and injuring him. Plaintiff brought this civil action alleging that Defendant's snowplow operator was negligent under Conn. Gen. Stat. 52-557n. The jury returned a verdict in favor of Plaintiff. The appellate court reversed, concluding that Plaintiff's sole remedy was an action pursuant to section 13a-149. The Supreme Court affirmed, holding that the appellate court correctly concluded that the highway defect statute was the exclusive remedy by which Defendant could recover for his injuries. View "Dobie v. City of New Haven" on Justia Law