American Trucking Associations v. City of Los Angeles: SCOTUS Issues Another FAAAA Preemption Decision

American Trucking Associations, Inc. v. City of Los Angeles, 569 U.S. ___ (6/13/13) is not an employment case, but it deals with FAAAA preemption, which has become prominent in many wage and hour actions and is pending before the California Supreme Court. Unfortunately (or perhaps fortunately, depending on your perspective) the holding in American Trucking is very narrow and does not shed much light on the issue before the California Supreme Court in People ex rel. Harris v. Pac Anchor Transportation, Inc. (Case No. S194388) (discussed discussed here).

In American Trucking, the United States Supreme Court considered whether the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempts certain requirements imposed by the City of Los Angeles on the trucks that move cargo into and out of the Port of Los Angeles. The parties agreed that the requirements are "related to a price, route, or service of any motor carrier . . . with respect to the transportation of property," leaving the Court only one issue to determine: whether the requirements "have the force and effect of law" and are preempted by the FAAAA. The Court held unanimously that the requirements do "have the force and effect of law" and are preempted.  The American Trucking opinion and related documents are available from SCOTUSblog here.  

American Trucking follows closely on the heals of another FAAAA preemption decision, Dan’s City Used Cars, Inc., v. Pelkey, 569 U. S. ____ (5/13/13) (discussed here).  In Dan's City, the Court held that state law claims stemming from the storage and disposal of a towed vehicle were not preempted because they were "related to neither the transportation of property nor the service of a motor carrier." The question at issue before the California Supreme Court in Pac Anchor relates more closely to the one decided in Dan's City: whether an action alleging that a trucking company violated the UCL by classifying its drivers as independent contractors is "related to the price, route, or service" of the company and, therefore, preempted by the FAAAA.  Pac Anchor has been fully briefed for about a year and is awaiting hearing.