Term: 2012
Docket: 11-798
American Trucking Associations, Inc., Petitioner v. City Of Los Angeles, California, Et Al.
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11-798 AMERICAN TRUCKING ASSOCIATIONS, INC. V. LOS ANGELES, CA, ET AL. DECISION BELOW: 660 F.3d 384 LIMITED TO QUESTIONS 1 AND 3 PRESENTED BY THE PETITION. CERT. GRANTED 1/11/2013 QUESTION PRESENTED: Title 49 U.S.C. § 14501(c)(1), originally enacted as a provision of the Federal Aviation Administration Authorization Act of 1994, provides that "a State [or] political subdivision . . . may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier ... with respect to the transportation of property." It contains an exception providing that the express preemption clause "shall not restrict the safety regulatory authority of a State with respect to motor vehicles." Id. § 14501(c)(2)(A). The questions presented are: 1. Whether an unexpressed "market participant" exception exists in Section 14501(c) (1) and permits a municipal governmental entity to take action that conflicts with the express preemption clause, occurs in a market in which the municipal entity does not participate, and is unconnected with any interest in the efficient procurement of services. 2. Whether a required concession agreement setting out various conditions a motor carrier must meet to serve a particular port imposes any requirements that are "related to a price, route, or service of any motor carrier" for the purposes of preemption under Section 14501(c)(1). 3. Whether permitting a municipal governmental entity to bar federally licensed motor carriers from access to a port operates as a partial suspension of the motor carriers' federal registration, in violation of Castle v. Hayes Freight Lines, Inc., 348 U.S. 61 (1954). LOWER COURT CASE NUMBER: 10-56465
In the 2012 case of American Trucking Associations, Inc. v. City of Los Angeles, California, the U.S. Supreme Court ruled in favor of the American Trucking Associations (ATA). The dispute centered around a concession agreement imposed by the Port of Los Angeles on trucking companies using its facilities as part of its Clean Trucks Program aimed at reducing air pollution. ATA argued that certain provisions in this agreement were pre-empted by federal law - specifically, a requirement for trucks to display placards with hotline numbers for reporting environmental or safety concerns and another provision requiring off-street parking for trucks not in service. The court agreed with ATA's argument that these requirements were indeed pre-empted by federal law under the Federal Aviation Administration Authorization Act (FAAAA) which prohibits states from enforcing laws related to price, route or service of motor carriers transporting property.
In the dissenting opinion for American Trucking Associations, Inc. v. City of Los Angeles, California et al., Justice Kagan disagreed with the majority's interpretation that federal law preempts certain provisions of a concession agreement between truck operators and the Port of Los Angeles. She argued that these provisions were not related to prices, routes or services as defined by federal law but rather they were part of a business deal in which both parties voluntarily agreed to specific terms in exchange for access to port facilities. Therefore, she believed there was no conflict with federal regulation and thus no reason for preemption. Furthermore, she noted that if such agreements could be preempted by federal law then it would limit local authorities' ability to manage their own property and negotiate contracts on their own terms.
