Justia Transportation Law Opinion Summaries

West Central Agri Services operates a grain handling facility in Missouri, where employees load grain into railcars by accessing the tops of the cars, which are about fifteen feet above the ground. Employees open and close lids on the railcars to facilitate grain transfer, and a Trackmobile moves the railcars into position. An OSHA inspector, investigating an unrelated explosion, discovered that employees frequently worked atop railcars without wearing fall protection personal protective equipment (PPE), despite the facility having a fall protection system in place on one track and safety training instructing use of such equipment. Supervisors were aware of the lack of PPE use, and employees were not disciplined for noncompliance.Following the investigation, the Secretary of Labor cited West Central for a willful and serious violation of 29 C.F.R. § 1910.132(d)(1)(i), which requires employers to ensure employees use appropriate PPE for identified hazards. After a three-day evidentiary hearing, an administrative law judge (ALJ) of the Occupational Safety and Health Review Commission upheld the citation and imposed a penalty of $122,878.80, finding that West Central recognized the fall hazard and failed to enforce PPE use. The Commission denied discretionary review of the ALJ’s decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the Federal Railroad Administration (FRA) has exercised statutory authority over the working conditions on top of railcars, specifically through its 1978 policy statement asserting jurisdiction over walking-working surfaces and employee protection around railcars. As a result, the FRA’s authority preempts OSHA’s jurisdiction under 29 U.S.C. § 653(b)(1). The court vacated the citation and reversed the ALJ’s order, concluding that OSHA cannot enforce its PPE regulation for employees working on top of railcars at this facility. View "MFA Enterprises, Inc. v. OSHRC" on Justia Law

An electronics technician employed by a regional transit authority was killed while working at a maintenance yard. His estate, through its administrator, brought suit against the transit authority and its parent entity, seeking recovery under the Federal Employers Liability Act (FELA), which provides a federal cause of action for employees of “common carriers by railroad” injured or killed during their employment. The transit line in question, known as the Speed Line, operates a 14.5-mile route between Philadelphia, Pennsylvania, and Lindenwold, New Jersey, providing frequent, high-capacity passenger service within a single metropolitan area. The Speed Line uses a third-rail electric system incompatible with other regional railroads, does not carry freight, and is not integrated with other rail lines.The United States District Court for the District of New Jersey initially denied the defendants’ motion to dismiss for lack of subject-matter jurisdiction, allowing jurisdictional discovery. After discovery, the District Court granted the renewed motion to dismiss, holding that the Speed Line is an urban rapid transit system rather than a railroad, and therefore FELA does not apply. The estate appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s legal conclusions de novo and its factual findings for clear error. The Third Circuit affirmed the District Court’s judgment, holding that the Speed Line is not a “common carrier by railroad” within the meaning of FELA. The court reasoned that the Speed Line’s services—short-haul, high-frequency passenger transportation within a single urban area—and its lack of integration with other railroads or freight operations, place it outside the scope of FELA. The court concluded that, as a rapid transit system, the Speed Line is not subject to FELA, and thus the federal courts lack subject-matter jurisdiction over the estate’s FELA claim. View "Estate of Schroeder v. Port Authority Transit Corp." on Justia Law

In 2020, the Transportation Security Administration (TSA) proposed a rule to address insider threats in airports, specifically targeting the risk that aviation workers with unescorted access to secured areas could facilitate the introduction of weapons or dangerous items onto aircraft. Instead of following the usual public notice-and-comment procedures required by the Administrative Procedure Act (APA), TSA provided notice and an opportunity to comment only to airport operators. The finalized rule, known as the National Amendment, required major airports to physically screen aviation workers entering certain secured areas and to acquire explosives-detection equipment. Noncompliance could result in civil enforcement actions by TSA.After TSA finalized the National Amendment in April 2023, various municipalities operating airports and a trade organization, Airport Council International-North America (ACI-NA), submitted timely requests for reconsideration, arguing that TSA lacked statutory authority, that the APA required public notice and comment, and that the rule unlawfully compelled local officials to implement a federal scheme. TSA denied all reconsideration requests, maintaining that its own regulations permitted it to amend airport security programs by providing notice and comment only to affected operators. The petitioners then sought review of TSA’s denial in the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit held that the National Amendment is a legislative rule subject to the APA’s notice-and-comment requirements, which TSA failed to follow. The court vacated the National Amendment but withheld its mandate, allowing TSA time to promulgate a procedurally proper rule or inform the court if no rule is needed. The court required TSA to submit periodic status reports until a final resolution. View "City of Billings v. TSA" on Justia Law

Two affiliated freight railroad companies challenged a series of security directives issued by the Transportation Security Administration (TSA) that required certain high-risk and strategically significant railroads to implement extensive cybersecurity measures. These directives, which were updated annually, imposed significant compliance costs and were motivated by ongoing and evolving threats from foreign adversaries such as Russia and China. The railroads argued that the directives should have undergone notice-and-comment rulemaking and that the ongoing nature of the cybersecurity threat did not constitute an “emergency” justifying bypassing those procedures.The petitioners sought direct review in the United States Court of Appeals for the Seventh Circuit, as permitted by statute, after the TSA issued new versions of the directives in May 2024, July 2024, and May 2025. The court consolidated the challenges because the directives were substantively identical. The railroads argued that TSA was required to conduct notice-and-comment rulemaking, perform a cost-benefit analysis, and that TSA lacked statutory authority to issue the directives. They also contended that the directives were arbitrary and capricious.The United States Court of Appeals for the Seventh Circuit denied the petitions. The court held that the ongoing cybersecurity threats described in the directives constituted an emergency within the meaning of 49 U.S.C. § 114(l)(2), allowing TSA to bypass notice-and-comment procedures. The court further held that TSA was not required to conduct a cost-benefit analysis for security directives, as the relevant statutory provision applied only to regulations, not directives. The court also found that TSA had sufficient statutory authority to issue the directives and that the directives were not arbitrary or capricious. The petitions for review were therefore denied. View "Grand Trunk Corp. v. Transportation Security Administration" on Justia Law

A United States citizen, formerly known as Paul Anderson and now Saadiq Long, was placed on the federal government’s Terrorist Screening Dataset (commonly called the Terrorist Watchlist) and, at one point, on its No Fly List subset. After experiencing travel restrictions, employment issues, and other alleged harms, Long challenged his placement on these lists, asserting constitutional and statutory violations. He claimed that his inclusion was based on impermissible factors such as race, religion, and protected activities, and that the government’s information-sharing practices and redress procedures were unlawful. While the litigation was ongoing, Long was removed from the No Fly List, but remained on the broader Watchlist. He also alleged that his Watchlist status led to the denial of credentials necessary for his work as a truck driver.The United States District Court for the Eastern District of Virginia initially transferred some of Long’s claims to the Fourth Circuit and stayed others. After Long’s removal from the No Fly List, a prior Fourth Circuit panel found his No Fly List claims moot and remanded for the district court to determine which claims remained justiciable. On remand, the district court dismissed all of Long’s claims for lack of subject matter jurisdiction, finding that his removal from the No Fly List mooted those claims and that he lacked standing for his Watchlist-related claims, as his alleged injuries were either resolved or not sufficiently imminent.The United States Court of Appeals for the Fourth Circuit vacated the district court’s dismissal. The Fourth Circuit held that, in light of the Supreme Court’s decision in FBI v. Fikre, Long’s removal from the No Fly List did not necessarily moot his claims, as the government had not shown it could not repeat the challenged conduct. The court also found that Long had standing to challenge his Watchlist status based on the denial of transportation credentials, and remanded for the district court to consider the merits of his claims. View "Long v. Bondi" on Justia Law

Three California-based truck drivers who worked for a national transportation company challenged the legality of their employer’s compensation system. The drivers alleged that the company’s pay plan, which combined hourly wages with a bonus based on certain activities, violated California’s Labor Code by failing to properly compensate for nonproductive time and by not reimbursing necessary business expenses, such as personal cell phone use. They also claimed the company failed to provide accurate wage statements and sought penalties under the Private Attorneys General Act (PAGA) and California’s Unfair Competition Law.After the case was removed from state court, the United States District Court for the Central District of California denied class certification and granted summary judgment to the employer on most claims. The court found that the pay plan qualified for a statutory “safe harbor” because it paid at least minimum wage for all hours worked, with additional bonuses for certain activities, and thus did not require separate compensation for nonproductive time. The court also found no evidence that the employer knew or should have known about any off-the-clock work. The only claims that proceeded to trial were for failure to reimburse business expenses. At trial, the jury found in favor of the employer, and the court entered judgment accordingly, also awarding costs to the employer.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the employer’s pay plan met the requirements of California Labor Code § 226.2(a)(7)’s safe harbor, as it paid at least minimum wage for all hours worked and provided additional bonuses. The court also found no genuine dispute of material fact regarding off-the-clock work or wage statement violations, and it upheld the district court’s evidentiary rulings, jury instructions, and award of costs. View "WILLIAMS V. J.B. HUNT TRANSPORT, INC." on Justia Law

A company that supplies oil and propane hired a trucking business to deliver 10,000 gallons of heating oil to its property in Putnam, Connecticut. During the delivery, the trucking company’s employee allegedly failed to monitor the filling process, resulting in an overflow that contaminated the soil and groundwater. The supplier claimed it incurred over $500,000 in remediation and related expenses due to the spill.The supplier filed a lawsuit in the United States District Court for the District of Connecticut, asserting common-law negligence and recklessness claims under Connecticut law. The complaint cited specific federal Hazardous Materials Regulations (HMRs) as evidence of the trucking company’s duties and alleged breaches. The trucking company moved to dismiss, arguing that the supplier’s claims were preempted by the federal Hazardous Materials Transportation Act (HMTA) and, alternatively, that the recklessness claim was insufficiently pleaded. The district court granted the motion, holding that the HMTA preempted the state-law claims and that the recklessness claim failed to state a claim.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The Second Circuit held that the HMTA does not preempt the supplier’s Connecticut common-law claims for negligence and recklessness, so long as those claims are based on duties that are “substantively the same” as federal requirements under the HMTA and HMRs. The court found that the mental state required for negligence and recklessness under Connecticut law is not inconsistent with the HMTA’s standards for civil violations. Accordingly, the Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "DCC Propane LLC v. KMT Enterprises, Inc." on Justia Law

The case involves José Ramón López Regueiro, who filed a lawsuit against American Airlines, Inc. under Title III of the Helms-Burton Act. Regueiro alleged that his father purchased Cuba’s main airport, which was later confiscated by Fidel Castro’s regime. Regueiro inherited his father’s interest in the airport and became a U.S. citizen in 2015. He claimed that American Airlines trafficked in the confiscated property by operating flights in and out of the airport.The United States District Court for the Southern District of Florida dismissed the case. The court agreed with American Airlines that the Helms-Burton Act implicitly required the property owner to be a U.S. citizen when the property was confiscated and the plaintiff to be a U.S. citizen when they acquired an interest in the property. Since Regueiro’s father was not a U.S. citizen when the airport was confiscated and Regueiro became a U.S. citizen only after inheriting the property, the court ruled that Regueiro failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s interpretation. The appellate court concluded that the Helms-Burton Act does not impose the preconditions that American Airlines argued. The Act provides a cause of action to any U.S. national who owns a claim to confiscated property, regardless of the owner’s citizenship status at the time of confiscation or acquisition. The court also rejected American Airlines’s argument that Regueiro’s ownership of shares in the company that owned the airport did not constitute an ownership interest in the airport itself. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Regueiro v. American Airlines, Inc." on Justia Law

Michael Muir, who has a congenital birth defect presenting as a hernia in his right scrotum, challenged the Transportation Security Administration’s (TSA) Final Rule authorizing the use of Advanced Imaging Technology (AIT) scanners at airport security checkpoints. Muir argued that the scanners, which use electromagnetic radiation, flag his hernia as a threat, leading to painful and potentially life-threatening pat-downs. He claimed that the Final Rule and TSA’s standard operating procedures (SOPs) are arbitrary and capricious, contrary to TSA’s statutory authority, and violate Section 504 of the Rehabilitation Act of 1973.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court found that Muir had not raised his statutory challenges during the rulemaking process, resulting in forfeiture of those claims. However, the court agreed with Muir’s Rehabilitation Act claim, noting that TSA’s failure to provide an accommodation for his disability could be a violation of the Act. The court determined that Muir had identified a reasonable accommodation—screening with a walk-through metal detector (WTMD)—and remanded the case to TSA to determine if this accommodation would impose an undue burden on the agency.The court denied Muir’s other challenges to the Final Rule and his motion to supplement the record. The court emphasized that TSA must conduct the appropriate administrative process to address the implementation of Muir’s reasonable accommodation and explore alternative accommodations if necessary. View "Muir v. Department of Homeland Security" on Justia Law

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt.The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law