Justia Transportation Law Opinion Summaries

The Court of Appeals affirmed in part and reversed in part the decision of the court of special appeals denying a motion for reconsideration of the circuit court's judgment reversing the decision of the County Board of Appeals of Anne Arundel County denying 808 Bestgate Realty, LLC's request for transportation impact fee credits, holding that remand was required.The transportation impact fee credits Bestgate sought was in connection with road improvements it made to a county road as part of a redevelopment project. The County's engineer administrator determined that the improvements provided transportation capacity that met the requirements of the County's standards applicable to roads, but the Board denied Bestgate's request for transportation impact fee credits. The circuit court reversed. The Court of Appeals reversed, holding (1) under the plain language of Md. Code Ann. 17-11-207(c), Bestgate was entitled to receive the requested transportation impact fee credits; and (2) the Board erred in its interpretation of the Code. View "Anne Arundel County v. 808 Bestgate Realty, LLC" on Justia Law

Norman Champine brought an action against the Michigan Department of Transportation in the Court of Claims alleging that defendant had breached its duty to maintain I-696. Plaintiff was driving on I-696 in Macomb County when a large piece of concrete dislodged from the road and crashed through the windshield of his car, causing serious injuries. The Court of Claims granted summary judgment in favor of defendant on the basis that plaintiff had failed to provide proper notice under MCL 691.1404. The court reasoned that plaintiff’s separate notice to defendant was inadequate because it was not filed in the Court of Claims, the complaint itself could not serve as notice, and the complaint had not identified the exact location of the highway defect. Plaintiff appealed, and the Court of Appeals affirmed in an unpublished per curiam opinion, holding that the filing of a complaint could not satisfy the statutory notice requirements. The Court of Appeals declined to address whether plaintiff also failed to adequately describe the location of the incident, even assuming plaintiff’s complaint could serve as proper notice. The Michigan Supreme Court determined “notice” was not defined by MCL 691.1404, so courts were permitted to consider its plain meaning as well as its placement and purpose in the statutory scheme. "The plain meaning of the word 'notice' in the context of the statute indicates only that the governmental agency must be made aware of the injury and the defect. The statute does not require advance notice beyond the filing of the complaint, and the Court of Appeals erred by holding otherwise. Plaintiff properly gave notice by timely filing his complaint in the Court of Claims." Nonetheless, the case had to be remanded to the Court of Appeals for that Court to address whether the complaint adequately specified the exact location and nature of the defect as required by MCL 691.1404(1). View "Champine v. Department of Transportation" on Justia Law

Dean McMaster brought a negligence action against DTE Energy Company, Ferrous Processing and Trading Company (Ferrous), and DTE Electric Company (DTE), seeking compensation for injuries he sustained when a metal pipe fell out of a scrap container and struck him in the leg. DTE, the shipper, contracted with Ferrous to sell scrap metal generated by its business. DTE and Ferrous moved for summary judgment, and the trial court granted the motion as to DTE but denied the motion as to Ferrous. McMaster settled with Ferrous and appealed with regard to DTE. The Court of Appeals affirmed, reasoning that DTE did not have a duty to warn of or protect McMaster from a known danger, relying on the open and obvious danger doctrine. McMaster sought leave to appeal to the Michigan Supreme Court, and the Supreme Court peremptorily vacated Part III of the opinion and remanded the case to the Court of Appeals for consideration of DTE’s legal duty under the law of ordinary negligence. On remand, the Court of Appeals again affirmed the trial court, finding that the common-law duty of a shipper was abrogated by Michigan’s passage of MCL 480.11a, which adopted the federal motor carrier safety regulations as part of the Motor Carrier Safety Act (the MCSA). The Supreme Court disagreed, holding that the common-law duty of care owed by a shipper to a driver was not abrogated by MCL 480.11a. As an issue of first impression, the Court adopted the “shipper’s exception” or “Savage rule” to guide negligence questions involving participants in the trucking industry, as this rule was consistent with Michigan law. Applying this rule, the Supreme Court affirmed on alternate grounds, the grant of summary disposition to DTE Electric Company (DTE) because there existed no genuine issue of material fact that DTE did not breach its duty to plaintiff. View "McMaster v. DTE Energy Company" on Justia Law

Iowa Northern Railway Company (“Iowa Northern”) and the International Association of Sheet Metal, Air, Rail and Transportation Workers (the “Union”) are both parties to a Collective Bargaining Agreement (“CBA”) that is subject to the Railway Labor Act (“RLA”). In 2019, Iowa Northern offered to increase the pay of unionized Train and Engine employees to $300 to recruit additional employees. The Union members rejected the pay increase. Subsequently, Iowa Northern served a Section 6 notice on the Union, proposing changes to the CBA. When the Union failed to respond, Iowa Northern provide notice it intended to resort to self-help, and then increased the pay rate to $300 per day.The Union then filed this case, claiming that Iowa Northern violated the RLA by unlawfully resorting to self-help and seeking a preliminary injunction to maintain the status quo prior to the pay-rate changes. The district court denied the Union's request, finding that it did not meet its burden of establishing the likelihood of success on the merits. The Union appealed.The Eighth Circuit affirmed the district court's denial of a Union's requested preliminary injunction, finding that the Defendant railway operator did not violate the Railway Labor Act when it resorted to self-help. The court explained the Union's "prolonged foot-dragging and refusal to respond on an issue of vital importance to Iowa Northern (and to the Union’s members) raise substantial doubt that the Union’s status quo claim will survive." View "Intl Assn of Sheet Metal, Air, Rail & Trans v. Iowa Northern Railway Company" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the ruling of the trial court that two private entities behind a high-speed rail between Houston and Dallas did not qualify as either railroad companies or interurban electric railway companies entitled to eminent-domain authority, holding that the entities had eminent-domain power as interurban electric railway companies.The owner of real property located along the proposed railway route sought a declaratory judgment that the two private entities lacked eminent-domain authority. The trial court granted summary judgment for the landowner. The court of appeals reversed, determining that the entities had eminent-domain power as both railroad companies and interurban electric railway companies. The Supreme Court affirmed, holding that the private entities had eminent-domain authority under Chapter 131 of the Texas Transportation Code. View "Miles v. Texas Central Railroad & Infrastructure, Inc." on Justia Law

The Supreme Court affirmed in part and vacated in part the decision of the court of appeals affirming the decision of the Iowa Department of Transportation (DOT) to rescind Petitioner's license under Iowa Code 322.3(12), holding that there was substantial evidence to revoke the motor vehicle dealer license.Petitioner, who owned and operated a vehicle dealership, pleaded guilty to one count of structuring transactions to avoid mandatory reporting requirements in violation of 31 U.S.C. 5324(a)(1) and (3) and was sentenced to a term of probation. The DOT then revoked Petitioner's Motor Vehicle Dealer License for a period of five years because of the structuring conviction. The district court upheld the revocation, stayed enforcement of the license revocation until the completion of the appeal, and tolled the entirety of the five-year revocation period. The court of appeals upheld the license revocation but determined that the district court lacked the authority to toll the five-year license revocation period. The Supreme Court held (1) there was substantial evidence to revoke the motor vehicle dealer license; and (2) the revocation period shall be extended by the length of the stay. View "Carreras v. Iowa Department of Transportation, Motor Vehicle Division" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the judgment of the district court affirming the decisions of the administrative law judge (ALJ) and the Iowa Department of Transportation (DOT) that good cause existed to permit a franchiser to create dueling franchises in a geographic area under Iowa Code 322A.4, holding that the district court did not err in its judgment.At issue was whether, in considering if the establishment of an additional franchisee in a geographic area is in the public interest, the DOT must consider the investment and impacts across the entire geographic area of the existing franchisee. The ALJ and DOT concluded that the twenty-three county area where the additional franchisee would compete with the existing franchisee was the relevant geographic area to consider when determining the presence of good cause under section 322A.4. The court of appeals reversed, arguing that the relevant geographic area to consider was the entire seventy-one county area in which the existing franchise conducted business. The Supreme Court vacated the decision below and affirmed the trial court, holding that the proper focus was the area in which the existing franchisee and the proposed new franchise would be in direct competition. View "Sioux City Truck Sales, Inc. v. Iowa Department of Transportation" on Justia Law

Freight shippers (“Plaintiffs”) alleged that the nation’s four largest freight railroads (“Defendants” or “Railroads”) have violated the Sherman Act, 15 U.S.C. Section 1, by engaging in a price-fixing conspiracy to coordinate their fuel surcharge programs as a means to impose supra-competitive total price increases on their shipping customers. Before hearing summary judgment motions, the District Court considered Defendants’ motions to exclude certain evidence on which Plaintiffs rely. Defendants argued the challenged documents were inadmissible under 49 U.S.C. Section 10706(a)(3)(B)(ii)(II) (“Section 10706”) as evidence of the Railroads’ discussions or agreements concerning “interline” traffic.   The D.C. Circuit affirmed in part and reversed in part the District Court’s interpretation of Section 10706, vacated the District Court’s order and remanded for the court to reconsider the evidence at issue. The court held that the District Court’s interpretation of Section 10706 sometimes strays from the literal terms of the statute.  The court reasoned that a discussion or agreement “concern[s] an interline movement” only if Defendants meet their burden of showing that the movements at issue are the participating rail carriers’ shared interline traffic. A discussion or agreement need not identify a specific shipper, shipments, or destinations to qualify for exclusion; more general discussions or agreements may suffice. Further, the court held that a carrier’s internal documents need not convey the substance of a discussion or agreement concerning interline movements to qualify for exclusion under the statute. View "In re: Rail Freight Fuel Surcharge Antitrust Litigation" on Justia Law

The four truckers who initiated this action regularly drove more than forty hours per week for their employer, JP Trucking, Inc., a Colorado transport company. The question they presented for the Colorado Supreme Courts review concerned whether they were entitled to overtime pay for hours exceeding forty hours per week or twelve hours per day. The Court surmised the answer depended on the meaning of a state regulation that exempted “interstate drivers” from overtime compensation. The truck drivers and JP Trucking both urged the Supreme Court to declare that the term “interstate drivers” was unambiguous: the truck drivers argued the term referred to drivers whose work predominantly took them across state lines; JP Trucking argued that “interstate drivers” were drivers involved in the transportation of goods in interstate commerce, even if their work never took them across state lines. A division of the Colorado court of appeals determined that “interstate drivers” was unambiguous from JP Trucking’s understanding of the term. The Supreme Court concluded the term was ambiguous, and consistent with a different appellate court division, held that “interstate drivers” refers to drivers whose work takes them across state lines, regardless of how often. Hence, the state exemption from overtime compensation was triggered the first time a driver crosses state lines during a work trip. The case was remanded for further proceedings, namely to allow the appeals court to consider JP Trucking’s remaining contentions regarding the calculation of damages. View "Gomez v. JP Trucking" on Justia Law

Defendant, Union Pacific, is a national rail carrier. Plaintiff, The Brotherhood of Locomotive Engineers and Trainmen ("BLET"), is a labor union representing Union Pacific engineers. Division 192 is the exclusive representative for Union Pacific employees around the area. An issue arose when an off-duty fistfight broke out during a union meeting between local division officers and an engineer. About two months after the fight, the engineer filed a complaint with Union Pacific, alleging that was threatened and assaulted by local division representatives in retaliation for taking extra shifts. The suspension of six union members effectively barred all of Division 192’s leadership from Union Pacific’s premises.BLET sued Union Pacific in federal court, alleging Union Pacific retaliated against the union for its shove policy. BLET argued the retaliation violated the section of the Railway Labor Act (“RLA”) prohibiting carrier interference with union activity.The court first found that federal courts have jurisdiction over post-certification disputes alleging that railroad conduct motivated by antiunion animus is interfering with the employees’ “choice of representatives.” Next, the court found that the facts support the determination that the union was likely to succeed in showing that the discipline was motivated by a desire to weaken the local division. Thus, the court found that the district court did not abuse its discretion in concluding that the union is likely to prevail in showing that Union Pacific’s suspension of effectively all the division’s elected representatives amounted to the prohibited interference under the RLA. View "BLET v. Union Pacific Railroad" on Justia Law