International Brotherhood of Teamsters v. Federal Motor Carrier Safety Administration, No. 18-73488 (9th Cir. 2021)
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The Ninth Circuit denied petitions for review of the FMCSA's determination that federal law preempted California’s meal and rest break rules (MRB rules), as applied to drivers of property-carrying commercial motor vehicles who are subject to the FMCSA's own rest break regulations.
The panel held that the agency's decision reflects a permissible interpretation of the Motor Carrier Safety Act of 1984 and is not arbitrary or capricious. Applying Chevron deference to the agency's interpretation of the statute and the phrase "on commercial motor vehicle safety," the panel held that even assuming petitioners identified a potential ambiguity in the statute, the agency's reading was a permissible one. In this case, the FMCSA reasonably determined that a State law "on commercial motor vehicle safety" is one that "imposes requirements in an area of regulation that is already addressed by a regulation promulgated under [section] 31136." Furthermore, the FMCSA's 2018 preemption decision also reasonably relied on Congress's stated interest in uniformity of regulation.
The panel concluded that the FMCSA permissibly determined that California's MRB rules were State regulations "on commercial motor vehicle safety," so that they were within the agency's preemption authority. The panel also concluded that the FMCSA faithfully interpreted California law in finding that California's rules were "additional to or more stringent than" federal regulations. Finally, the panel concluded that the agency did not act arbitrarily or capriciously in finding that enforcement of the MRB rules "would cause an unreasonable burden on interstate commerce."
Court Description: Federal Motor Carrier Safety Administration. The panel denied petitions for review of the Federal Motor Carrier Safety Administration (“FMCSA”)’s determination that federal law preempted California’s meal and rest break rules (the “MRB rules”), as applied to drivers of property-carrying commercial motor vehicles who are subject to the FMCSA’s own rest break regulations. The FMCSA only has the authority to review for preemption State laws and regulations “on commercial motor vehicle safety.” 49 U.S.C. § 31141(c). The panel held the agency’s interpretation of the statute and the phrase “on commercial motor vehicle safety” merited deference under Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), where the FMCSA acknowledged that it was departing from its 2008 interpretation of § 31141 and provided a reasoned analysis why it was doing so. The panel rejected petitioners’ arguments that Chevron deference was inapplicable. Turning to Chevron’s two-step framework, the panel held that even assuming petitioners identified a potential ambiguity in the statute, the agency’s reading was a permissible one. The FMCSA reasonably determined that a State law “on commercial motor vehicle safety” was one that “imposes requirements in an area of regulations that is IBT V. FMCSA 5 already addressed by a regulation promulgated under [section] 31136.” 83 Fed. Reg. at 67,473 (Dec. 28, 2018). The FMCSA’s 2018 preemption decision also reasonably relied on Congress’s stated interest in uniformity of regulation. The fact that California regulated meal and rest breaks in a variety of industries did not compel the conclusion that the MRB rules were not “on commercial motor vehicle safety.” Finally, the panel held that the decision in Dilts v. Penske Logistics, LLC, 769 F.3d 637 (9th Cir. 2014), did not foreclose the FMCSA’s interpretation. The panel concluded that the FMCSA permissibly determined that California’s MRB rules were State regulations “on commercial motor vehicle safety,” so that they were within the agency’s preemption authority. The panel held that the FMCSA’s determination that the MRB rules were “additional to or more stringent than” the federal regulation was reasonable and supported. 49 U.S.C. § 31141(c)(1). The FMCSA reached this conclusion because California required more breaks, more often and with less flexibility as to timing. The panel rejected petitioners’ challenges to this determination. The panel held that the FMCSA did not act arbitrarily or capriciously in finding that enforcement of the MRB rules “would cause an unreasonable burden on interstate commerce.” 49 U.S.C. § 31141(c)(4)(C). Petitioners’ counterarguments did not show that the agency acted arbitrarily or capriciously.
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