Justia Transportation Law Opinion Summaries

An Illinois state agency oversees Metra, a railroad with passenger service over lines radiating from Chicago. For three lines, Metra owns the rolling stock, while Union Pacific supplies the track, the workforce, and ticket sales. Ticket revenue goes to Metra, which pays UP for its services. UP notified Metra that it would discontinue its services. Metra replied that UP cannot drop the service unless relieved of its obligations by the Surface Transportation Board. Metra argued that UP is locked into its relationship with Metra because the 1995 ICC Termination Act repealed 49 U.S.C. 10908, 10909, the only statutes giving the Board authority over the discontinuation of passenger service. UP argued that the repeal deregulated passenger rail service so that railroads can end passenger service when business considerations dictate. Federal law requires the Board’s permission to abandon all service over a line of track but UP will continue freight service; the lines will not be abandoned.The district court declined to defer to the Board’s primary jurisdiction because the dispute does not require any findings of fact by an agency. The Board agreed. The Seventh Circuit affirmed in favor of UP. The controlling contract has long expired. Any reduction in service, therefore, depends on “compliance with all applicable statutory and regulatory provisions.” To the extent that UP is a common carrier—rather than an independent contractor of Metra—it has unfettered authority to discontinue any service without the Board’s approval if it keeps the rails in place and continues running some trains. View "Union Pacific Railroad Co. v. Regional Transportation Authority" on Justia Law

The Supreme Court granted Relator's request for a writ of mandamus ordering the Ohio Department Transportation and its director (collectively, ODOT) to begin appropriation proceedings for the taking of real property owned by Relator, holding that appropriation proceedings were necessary.ODOT's roadway construction project resulted in Relator's property being inaccessible from any road. Relator filed this action seeking a writ of mandamus ordering ODOT to commence appropriation proceedings pursuant to Ohio Rev. Code 163. ODOT argued in response that Relator could obtain a permit from the city of Cleveland to connect the property to a road and that Relator must apply for and be denied such a permit before he was entitled to mandamus. The Supreme Court granted Relator's request for a writ of mandamus and ordered ODOT to commence appropriation proceedings, holding that Relator was entitled to a writ compelling ODOT to commence appropriation proceedings. View "State ex rel. Balunek v. Marchbanks" on Justia Law

Five people were killed when a commercial truck rear-ended a line of traffic on an interstate highway. The truck driver was prosecuted and sentenced to prison for his misconduct. The issue on this appeal was the liability, if any, of the manufacturer of the truck. Plaintiffs, suing on behalf of the heirs and estates of the decedents, contended the manufacturer, Daimler Trucks North America, should have been held liable in tort under design-defect and warning-defect theories of products liability because it failed to equip the truck with two collision-mitigation systems—forward-collision warning and automatic emergency braking—and did not warn of the dangers caused by that failure. The district court granted summary judgment to Daimler. After its review of the district court record, the Tenth Circuit Court of Appeals affirmed, finding many of the arguments made by Plaintiffs on appeal were inadequately preserved for appellate review, and the remaining arguments lacked merit. View "Butler, et al. v. Daimler Trucks North America" on Justia Law

In a challenge to the San Francisco Municipal Transportation Agency’s policy of towing safely and lawfully parked vehicles without a warrant based solely on the accrual of unpaid parking tickets, the Coalition argued that the warrantless tows are unreasonable seizures within the meaning of article I, section 13 of the California Constitution and the Fourth Amendment to the U.S. Constitution. The trial court denied a motion for a writ of mandate and declaratory and injunctive relief.The court of appeal reversed. The challenged warrantless tows are not permissible under the vehicular community caretaking exception to the Fourth Amendment’s warrant requirement. The defendants have not shown that legally parked cars with unpaid parking tickets that present no threat to “public safety and the efficient movement of vehicular traffic” may be towed under that exception. The court rejected an argument that the governmental interest in deterring parking violations and nonpayment of parking fines justifies warrantless tows under the vehicular community caretaking exception. The tows at issue may not be justified by analogy to warrantless property seizures in the forfeiture context. View "Coalition on Homelessness v. City and County of San Francisco" on Justia Law

Ye sought to recover against GlobalTranz, a freight broker, following the death of her husband in a highway accident. Ye claimed, under Illinois law, that GlobalTranz negligently hired the motor carrier (Sunrise) that employed the driver of the truck that caused the accident. Ye obtained a $10 million default judgment against Sunrise.The district court concluded that the Federal Aviation Administration Authorization Act’s express preemption provision in 49 U.S.C. 14501(c)(1) bars Ye’s claim against GlobalTranz and that the Act’s safety exception in 14501(c)(2)(A) does not save the claim. The Seventh Circuit affirmed, noting the significant economic effects that would result from imposing state negligence standards on brokers. Congress broadly disallowed state laws that impede its deregulatory goals, with a specific carveout for laws within a state’s “safety regulatory authority." Ye’s negligent hiring claim against GlobalTranz falls within 14501(c)(1)’s express prohibition on the enforcement of state laws “related to a ... service of any ... broker ... with respect to the transportation of property.” Rejecting the "safety exception" claim, the court reasoned that a common law negligence claim enforced against a broker is not a law that is “with respect to motor vehicles." View "Ye v. GlobalTranz Enterprises, Inc." on Justia Law

The First Circuit affirmed the determination of the Title III court, during the course of its confirmation of the Modified Fifth Amended Title III Plan of Adjustment (Plan) for the Puerto Rico Highways and Transportation Authority (PRHTA), that the Vazquez-Valezquez Group's claims for additional compensation made in a separate federal lawsuit were dischargeable, holding that there was no error.The Group, which was composed of sixty-nine current and former PRHTA employees who received extra compensation under PRHTA Regulation 12-2017, with which the PRHTA later broke. At issue was the Group's objection to the Title III court's determination that the Group's claims for additional compensation were dischargeable under the Plan. After the Title III court entered an order and judgment confirming the plan the Group appealed, arguing that its members' claims were nondischargeable. The First Circuit affirmed, holding that the claims for additional compensation were not exempt from discharge. View "Financial Oversight & Management Bd. v. Vazquez-Velazquez Group" on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Puerto Rico Highways and Transportation Authority (PRHTA) and its executive directors (collectively, Appellees) and dismissing this complaint brought by sixty-nine current and former employees of the PRHTA (collectively, Appellants), holding that the district court did not err or abuse its discretion.Appellants brought this action challenging the PRHTA's decision no longer to give effect to a regulation providing Appellants with additional compensation. Specifically, Appellants claimed that the decision was contrary to P.R. Act No. 66-2014, giving rise to violations of the Contracts Clause and Due Process Clause. The district court granted summary judgment for the PRHTA on the federal constitutional claims and declined to exercise supplemental jurisdiction over Appellants' claims under Puerto Rico law. The First Circuit affirmed, holding that the district court (1) did not err in concluding that Appellants could not establish their federal constitutional claims; and (2) did not abuse its discretion in declining to exercise jurisdiction over Appellants' remaining Puerto Rico law claims. View "Vazquez-Velazquez v. P.R. Highway & Transportation Authority" on Justia Law

Jaranowski worked as a conductor for the Railroad for 22 years. While operating a railroad switch in 2020, he seriously injured his neck. He sued the railroad under the Federal Employers’ Liability Act (FELA), 45 U.S.C. 51, alleging that he was injured because the railroad failed to maintain the switch properly. He accused the railroad of ordinary negligence and negligence per se based on alleged violations of Federal Railroad Administration (FRA) Track Safety Standards, 49 C.F.R. 213. The district court concluded that Jaranowski had failed to present evidence that would support a finding that the railroad had actual or constructive notice of any defect in the switch before he was injured and granted the Railroad summary judgment.The Seventh Circuit reversed. Actual or constructive notice is required to violate the federal Track Safety Standards, however, Jaranowski presented sufficient evidence to create a genuine dispute as to whether the railroad at least should have known that the switch was defective before he was injured. A reasonable jury could accept Jaranowski’s account of the facts and the report of his expert, who examined the switch, to conclude that the Railroad’s prior inspection was performed without due care. View "Jaranowski v. Indiana Harbor Belt Railroad Co." on Justia Law

Norfolk Southern Railway Company (Norfolk Southern) petitioned for review of a decision of the Surface Transportation Board (STB or Board), the successor agency to the Interstate Commerce Commission (ICC) charged with authorizing certain rail carrier transactions under the Interstate Commerce Act. Norfolk Southern is a rail carrier that owns a 57.14 percent share of the Norfolk & Portsmouth Belt Line Railroad Company (Belt Line), the operator of a major switching terminal in Norfolk, Virginia. Norfolk Southern’s majority interest goes back to 1982, when its corporate family acquired and consolidated various rail carriers with smaller ownership interests in the Belt Line. Norfolk Southern’s competitor, CSX Transportation, Inc. (CSX), owns the remainder of the Belt Line’s shares (42.86 percent). This case involves a different question raised before the Board for the first time:  whether the ICC/Board approvals of Norfolk Southern’s subsequent corporate-family consolidations in 1991 and 1998 authorized Norfolk Southern to control the Belt Line. The Board again answered no. Norfolk Southern petitioned for review.   The DC Circuit affirmed. The court concluded that the Board’s decision regarding the 1991 and 1998 transactions is neither arbitrary nor capricious. The Board reasonably sought to avoid an absurd interpretation of 49 C.F.R. Section 1180.2(d)(3)’s corporate-family exemption that would allow a carrier to gain control of a new entity without following the Board’s review requirements and then “cure that unauthorized acquisition by reorganizing the corporate family.” The Board reasonably rejected Norfolk Southern’s claim that, by reshuffling the pieces of its corporate family, it acquired control authority of the Belt Line sub silentio. View "Norfolk Southern Railway Company v. STB" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss the underlying complaint in its entirety, holding that the district court did not err in finding that the challenged regulations in this case were not null and remained enforceable and that there is no private right of action to enforce the Puerto Rico Oversight Management Stability Act (PROMESA), 48 U.S.C. 2101.Plaintiff, Camara de Mercadeo, Industria y Distribución de Alimentos, Inc., filed the underlying complaint on behalf of its members - businesses in the food industry - seeking declaratory and injunctive relief from certain regulations related to freight tariffs and implementing circular letters promulgated by the Commonwealth of Puerto Rico's Transportation and other Public Services Bureau. Specifically, Plaintiff alleged that the challenged regulations were unlawful under PROMESA. The district court granted Defendants' motion to dismiss. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on its allegations of error. View "Camara de Mercadeo v. Emanuelli Hernandez" on Justia Law