Dilts v. Penske Logisitics LLC et al.
CASES RELATED BY THIS ISSUE
The panel held that California's meal and break laws were not preempted by the Federal Aviation Administration Authorization Act
NCLC urged the Ninth Circuit to hold that state meal and rest break laws that significantly affect motor carriers’ costs are preempted by the Federal Aviation Administration Authorization Act (“FAAAA”). In this case, the plaintiff-appellants sued the defendant-appellee company on behalf of a putative class claiming that the company failed to provide drivers with rest and meal periods required under California law. The District Court ruled that enforcement of California’s meal and rest period laws would affect a motor carrier’s prices, routes or services, and are preempted by federal transportation law. In its amicus brief, NCLC argues state laws, like the California law at issue here, that impose significant additional costs on motor carriers are preempted in the FAAAA context because those costs are closely connected to carrier prices, which are governed under the FAAAA. Additionally, NCLC argues that Supreme Court precedent establishes that FAAAA preemption applies whenever the state law at issue would force carriers to modify the manner in which they undertake deliveries, thereby interfering with the outcome that competitive market forces would otherwise dictate.
The panel reversed the district court's dismissal, based on federal preemption, of claims brought by a certified class of drivers alleging violations of California's meals and rest break laws. The panel held that California's meal and rest break laws as applied to the motor carrier defendants were not "related to" defendants' prices, routes, or services, and therefore they were not preempted by the Federal Aviation Administration Authorization Act of 1994.
NCLC amicus brief filed 11/16/12. Decided 7/9/2014.