Term: 2004
Docket: 03-1234
Mid-con Freight Systems, Inc., Et Al. v. Michigan Public Service Commission, Et Al.
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03-1234 MID-CON FREIGHT SYSTEMS V. MICHIGAN PUBLIC SERVICE COMM'N DECISION BELOW: 662 NW2d 784 ORDER OF 1/21/2005: LIMITED TO THE FOLLOWING QUESTIONS: 1) “Whether the $100 fee upon vehicles conducting intrastate operations violates the Commerce Clause of the United States Constitution.” 2) “Whether the $100 fee upon vehicles operating solely in interstate commerce is preempted by 49 U.S.C. §14504.” CONCOLIDATED WITH 03-1230 FOR ONE HOUR ORAL ARGUMENT. CERT. GRANTED 1/14/2005 QUESTION PRESENTED: May States avoid the $10 per-vehicle fee cap of the expressly preemptive Single State Registration System (and its predecessor "bingo card" program) by charging $100 per vehicle to certain interstate motor carriers and calling the charge a "regulatory fee?" LOWER COURT CASE NUMBER: 226052, 226122, 226053, 226137
The case of Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission in 2004 revolved around the issue of whether or not a state could impose its own regulations on interstate trucking companies that were already subject to federal regulation under the Federal Aviation Administration Authorization Act (FAAAA). The Supreme Court ruled in favor of Mid-Con Freight Systems, stating that states cannot enforce their own laws and regulations on interstate trucking firms if those rules are related to prices, routes or services - areas which fall under federal jurisdiction according to FAAAA. This decision reinforced the principle of federal preemption over state law when it comes to regulating interstate commerce.
In the dissenting opinion for the case Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission, it was argued that federal law does not preempt state regulation of intrastate towing rates charged by motor carriers participating in interstate commerce. The dissent emphasized that Congress did not intend to eliminate all state authority over these matters when it enacted the Federal Aviation Administration Authorization Act (FAAAA). Instead, they believed Congress intended to prevent states from undermining federal deregulation of interstate trucking through inconsistent or burdensome regulations but still allowed them some regulatory power over intrastate activities. They also pointed out that there is a presumption against preemption where congressional action would upset a long-standing balance between state and federal control over an area traditionally regulated by states - such as local transportation services like towing.
