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Appeals court upholds FMCSA preemption over California meal/rest breaks

ATA calls ruling ‘victory for common sense over bureaucracy’

California rest break laws preempted by federal HOS regs. (Photo: Jim Allen/FreightWaves)

The U.S. Court of Appeals for the 9th Circuit has upheld a determination by the Federal Motor Carrier Safety Administration (FMCSA) that California cannot enforce state meal and rest break (MRB) rules that conflict with federal hours-of-service regulations.

The FMCSA’s determination, made in December 2018, granted petitions submitted by the American Trucking Associations and the Specialized Carriers and Rigging Association and was quickly appealed by the International Brotherhood of Teamsters and the state of California.

But the three-judge panel held that the agency’s interpretation of federal statutes “merited deference” and rejected the petitions by the Teamsters and the state.

“The court’s ruling is a victory for common sense over bureaucracy and the plaintiffs bar,” commented ATA President and CEO Chris Spear.

“When the Department of Transportation preempted California’s rules, it was a victory for highway safety, ensuring that there is one uniform standard for trucking regulations. By upholding DOT’s authority to be the sole regulator of interstate trucking, the 9th Circuit is preventing states and trial lawyers from creating a costly and inefficient patchwork of competing rules.”

A Teamsters spokesman told FreightWaves that the union had no comment on the court’s ruling.

The crux of the Teamster’s arguments against FMCSA’s ruling, noted the law firm Scopelitis, Garvin, Light, Hanson & Feary, was that the agency had determined under a previous administration that it lacked authority to consider laws that were not specifically aimed at commercial truck safety.

“The court noted that FMCSA is free to change its mind, provided it acknowledges it is doing so and explains the reasons for its new position,” according to Scopelitis. “Because the federal hours-of-service regulations were promulgated under statutory authority to prescribe regulation ‘on commercial motor vehicle safety,’ the court found it reasonable to interpret [federal statute] to cover regulations in that same area.”

Scopelitis also noted the appeals court’s citing carrier comments that showed the impact of the MRB rules on their operations as justifying FMCSA’s conclusion that the MRB rules “unreasonably burden” interstate commerce.

“We hope this ruling sends a strong message to other states that they are not allowed to impose additional regulatory burdens on interstate commerce,” Spear said. “We thank DOT and the court for upholding the principle that federal regulatory primacy is critical for maintaining safe and efficient transportation.”

The FMCSA reached a similar conclusion in November regarding MRB rules in Washington state through the granting of a petition filed in 2019 by the Washington Trucking Associations, which had sought a determination. The Teamsters is “re-evaluating our options in light of the recent 9th Circuit decision,” the union’s spokesman said.

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John Gallagher

Based in Washington, D.C., John specializes in regulation and legislation affecting all sectors of freight transportation. He has covered rail, trucking and maritime issues since 1993 for a variety of publications based in the U.S. and the U.K. John began business reporting in 1993 at Broadcasting & Cable Magazine. He graduated from Florida State University majoring in English and business.