Dilts v. Penske Logistics, Inc., No. 12-55705 (9th Cir. 2014)
Annotate this CasePlaintiffs filed a class action against defendants, motor carriers, alleging that defendants routinely violate California's meal and rest break laws, Cal. Lab. Code 226.7, 512; Cal. Code Regs. tit.8, 11090. The district court held on summary judgment that the Federal Aviation Administration Authorization Act of 1994, 49 U.S.C. 14501(c)(1), preempts those state laws as applied to motor carriers. The court concluded that the Act does not preempt California's meal and rest break laws as applied to defendants because those laws are not related to defendants' prices, routes, or services. Accordingly, the court reversed and remanded.
Court Description: Federal Preemption. 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 meal 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. District Judge Zouhary concurred, and wrote separately to emphasize that the defendant failed to carry its burden of proof on its preemption defense.
The court issued a subsequent related opinion or order on September 8, 2014.
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