Massachusetts Delivery Ass’n v. Healey, No. 15-1908 (1st Cir. 2016)Annotate this Case
The Massachusetts Delivery Association (MDA), a trade organization representing same-day delivery companies in Massachusetts, brought this suit on behalf of its members seeking a declaration that “Prong 2” of the Massachusetts Independent Contractor Statute is preempted by the Federal Aviation Administration Authorization Act (FAAAA) as well as an injunction barring the Attorney General from enforcing Prong 2 against its members. After the First Circuit twice remanded the case, the district court held that the FAAAA preempts Prong 2 as to the members of the MDA as a matter of logical effect. Applying the logic of the First Circuit's decision in Schwann v. FedEx Ground Package System, Inc., the First Circuit affirmed, holding that the application of Prong 2 to the members of the MDA is preempted by the FAAAA.