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A local government has the authority under Fla. Stat. 316.0083(1)(a) to contract with a private third-party vendor to review and sort information from red light cameras, in accordance with the local government’s written guidelines, before sending that information to a trained traffic enforcement officer, who determines whether probable cause exists and a citation should be issued. Petitioner received a traffic citation based on images from a red light camera. Petitioner argued that the City of Aventura’s red light camera enforcement program was illegal because it included the use of a third-party agent to review images from the City’s red light cameras before sending them to City police to determine whether a traffic citation should be issued. The court of appeal held that the City did not violate the Mark Wandall Traffic Safety Program, see Fla. Stat. 316.0083(1)(a), which grants local governments’ traffic enforcement officers the power to issue citations for traffic infractions captured by red light cameras. The Supreme Court affirmed, holding that the City did not exceed its statutory authority in contracting with a vendor to review the red light camera images and that the City’s use of its own standards for determining whether a traffic infraction has occurred did not violate the uniformity principle set forth in chapter 316. View "Jimenez v. State" on Justia Law

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Plaintiff filed suit against defendants for violation of the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-2725. The Eleventh Circuit held that the DPPA permitted punitive damages against municipal agencies; the district court did not abuse its discretion when it assessed liquidated damages for both occasions when Defendant Thomas accessed plaintiff's information; the district court did not abuse its discretion when it declined to certify a class action; the district court did not abuse its discretion when it declined to grant a new trial; and the district court did not err when it instructed the jury that punitive damages should bear a reasonable relationship to compensatory damages. View "Truesdell v. Thomas" on Justia Law

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The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary roads. The enforcement of the IDOT’s rules resulted in three cities being ordered to relocate or remove several of their ATE cameras. The district court upheld both the IDOT’s rules and its decisions based on those rules. The Supreme Court reversed, holding that the rules were invalid and could not be enforced against the cities because the IDOT’s specific grants of authority did not support the rules. View "City of Des Moines v. Iowa Department of Transportation" on Justia Law

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The Iowa Department of Transportation (IDOT) did not have the statutory authority from the legislature to promulgate administrative rules regulating automated traffic enforcement (ATE) systems located along primary roads. The enforcement of the IDOT’s rules resulted in three cities being ordered to relocate or remove several of their ATE cameras. The district court upheld both the IDOT’s rules and its decisions based on those rules. The Supreme Court reversed, holding that the rules were invalid and could not be enforced against the cities because the IDOT’s specific grants of authority did not support the rules. View "City of Des Moines v. Iowa Department of Transportation" on Justia Law

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Alabama rail carriers pay a 4% sales and use tax on diesel fuel. Motor carriers and water carriers are exempt from that tax but motor carriers pay a Motor Fuels Excise Tax of $0.19 per gallon of diesel. Water carriers pay no tax for diesel fuel. The Eleventh Circuit previously determined that Alabama failed to sufficiently justify the scheme under the Railroad Revitalization and Regulatory Reform Act, 49 U.S.C. 11501, which forbids states from discriminating against rail carriers in assessing property or imposing taxes. The Supreme Court reversed and remanded. On remand, the district court again ruled that Alabama’s tax scheme does not violate the Act. The Eleventh Circuit then reversed. The excise tax justifies the motor carrier exemption. As to water carriers, their exemption is not “compelled by federal law.” Although imposing the sales and use tax on water carriers transporting freight interstate might “expose” the state to a lawsuit under federal law, compulsion requires more than exposure. The water carrier exemption is “compelled by federal law” only if imposition of the sales and use tax would violate federal law. It would not, so it violates the Act. View "CSX Transportation, Inc. v. Alabama Department of Revenue" on Justia Law

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In 2008, a Jefferson County Public Transportation Benefit area vehicle collided with Michael Gilmore's vehicle. Gilmore brought a personal jury lawsuit against Jefferson Transit for injuries he allegedly sustained in that collision. At trial, he was awarded $1.2 million for past and future economic losses. Jefferson Transit appealed, arguing the trial court abused its discretion in admitting certain evidence, barring certain evidence, and in determining Gilmore's counsel's closing arguments did not require a new trial. The Court of Appeals reversed as to all issues Jefferson Transit raised. The Washington Supreme Court reversed the Court of Appeals. The Supreme Court found no abuse of discretion with respect to the evidence admitted at trial, "[w]e will not disturb the trial court's decision unless 'such a feeling of prejudice [has] been engendered or located in the minds of the jury as to prevent a litigant from having a fair trial." With respect to closing arguments, the Supreme Court nothing in the record suggested it was incurably prejudicial. "By rationalizing Gilmore's counsel's statements as 'technique' and failing to object after being given several opportunities, it is clear that Jefferson Transit's counsel perceived no error and was 'gambling on the verdict.'" View "Gilmore v. Jefferson County Pub. Transp. Benefit Area" on Justia Law

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The Second Circuit affirmed the district court's dismissal of a claim alleging that the New York State Thruway Authority violated the Dormant Commerce Clause when it used surplus revenue from highway tolls to fund the State of New York's canal system. The court held that Congress evinced an "unmistakably clear" intent to authorize the Thruway Authority to depart from the strictures of the Dormant Commerce Clause by allocating surplus highway toll revenues to New York's Canal System. The court explained that Congress placed no limits on the amount of such surplus highway toll revenue that the Thruway Authority could allocate to the Canal System. Finally, the court held that the district court had discretion to reach the merits of the Thruway Authority's defense that Congress had authorized it to devote surplus highway toll revenues to the Canal System. View "American Trucking Ass'ns, Inc. v. N.Y. State Thruway Authority" on Justia Law

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Philadelphia taxicabs were required to have a medallion and a certificate of public convenience, which required that vehicles be insured and in proper condition, and mandated that drivers be paid the prevailing minimum wage, be proficient in English, and have appropriate drivers’ licenses. In 2014, 1610 medallions were each worth about $545,000. Uber began operating in Philadelphia without securing medallions or certificates, providing an app to schedule and pay for a ride. Uber does not own or assume responsibility for the vehicles, nor does it hire drivers. A 2016 Pennsylvania law approved Transportation Network Companies (TNCs) using digital apps. TNCs must obtain licenses and comply with insurance and safety standards but set their own fares. Medallion taxicab companies comply with established rates, minimum wages, and have a limited number of vehicles. Nearly 1200 Philadelphia medallion taxicab drivers left their companies to drive for Uber. Medallion taxi rides reduced by about 30 percent. The value of each medallion dropped to approximately $80,000. Taxicab drivers sued under the Sherman Act, 15 U.S.C. 2. The Third Circuit affirmed the dismissal of the complaint. Inundating the market with Uber vehicles, even if it eliminated competitors, was not anticompetitive; it bolstered competition by offering customers lower prices, more availability, and a high-tech alternative to customary practices. Uber’s ability to operate at a lower cost is not anticompetitive. Uber’s business model does not reflect specific intent to monopolize. Plaintiffs also failed to allege antitrust standing. View "Philadelphia Taxi Association, Inc. v. Uber Technologies Inc" on Justia Law

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The Railroad Revitalization and Regulatory Reform Act prohibits states from imposing a tax that discriminates against a rail carrier. 49 U.S.C. 11501(b)(4). The Eleventh Circuit held that Alabama's tax scheme, which imposes either a sales or use tax on rail carriers when they buy or consume diesel fuel but exempts competing motor and water carriers from those taxes, violates the Act as to water carriers, but not to motor carriers. The court held that the district court correctly concluded that the excise tax was roughly equivalent to the sales and use tax and thus the excise tax justified the motor carrier sales-tax exemption. However, unlike the motor carrier exemption, the State could offer no rough equivalency justification for the water carrier exemption because water carriers pay no state taxes at all when they buy or consume diesel. View "CSX Transportation, Inc. v. Alabama Department of Revenue" on Justia Law

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The Eleventh Circuit reversed the district court's grant of summary judgment against two transportation companies, Barrett and Landstar, in an action by Nationwide and its insurer, Essex, seeking to recover loss of an MRI under the Carmack Amendment, 49 U.S.C. 14706 et seq. The court held that the Magistrate Judge applied the correct standard for distinguishing brokers from carriers, but that there was a genuine factual dispute as to whether Barrett accepted legal responsibility to transport the magnet or communicated to Nationwide that it was brokering the shipment of the magnet to a third party. The court applied the holding in Werner Enterprises, Inc. v. Westwind Maritime International, Inc., 554 F.3d 1319 (11th Cir. 2009), to this case, and held that Landstar was entitled to rely on the Broker-Carrier Agreement's (BCA) limitation of liability, because the BCA satisfied the Carmack Amendment's requirements. In this case, Landstar was entitled to the $1.00 per pound liability limitation in the bill of lading. Therefore, the court remanded for further proceedings. View "Essex Insurance Co. v. Barrett Moving & Storage, Inc." on Justia Law