Miller v. C.H. Robinson Worldwide, Inc., No. 19-15981 (9th Cir. 2020)
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After plaintiff suffered serious injuries when he was struck by a semi-tractor trailer, he filed suit against C.H. Robinson, the freight broker that arranged for the trailer to transport goods for Costco. Plaintiff alleged that C.H. Robinson negligently selected an unsafe motor carrier.
The Ninth Circuit agreed with the district court that plaintiff's claim is "related to" C.H. Robinson's services, but held that the district court erred in determining that the Federal Aviation Administration Authorization Act of 1994's (FAAAA) safety exception does not apply. The panel explained that, in enacting that exception, Congress intended to preserve the States’ broad power over safety, a power that includes the ability to regulate conduct not only through legislative and administrative enactments, but also though common-law damages awards. The panel also held that plaintiff's claim has the requisite "connection with" motor vehicles because it arises out of a motor vehicle accident. Therefore, the negligence claims against brokers, to the extent that they arise out of motor vehicle accidents, have the requisite "connection with" motor vehicles, and thus the safety exception applies to plaintiff's claims against C.H. Robinson. The panel reversed and remanded.
Court Description: Federal Aviation Administration Authorization Act of 1994 The panel reversed the district court’s dismissal, based on the Federal Aviation Administration Authorization Act of 1994 (“FAAAA”)’s preemption, of plaintiff’s state law claim alleging that C.H. Robinson Worldwide, Inc. negligently selected an unsafe motor carrier resulting in plaintiff’s serious injuries in a motor vehicle accident. The FAAAA preempts state laws that are “related to a price, route, or service of any . . . broker,” unless one of the FAAAA’s exceptions applies. The district court found plaintiff’s claim preempted under the FAAAA because it was “related to” C.H. Robinson’s services and did not fall within the exception for “the safety regulatory authority of a State with respect to motor vehicles.” * The Honorable Susan R. Bolton, United States District Judge for the District of Arizona, sitting by designation. MILLER V. C.H. ROBINSON WORLDWIDE 3 The panel agreed with the district court that plaintiff’s claim was “related to” C.H. Robinson’s broker services, but held that the district court erred in holding that the safety exception did not apply. The panel held that in enacting the exception, Congress intended to preserve the States’ broad power over safety, a power that included the ability to regulate conduct not only through legislative and administrative enactments, but also through common law damages. The panel further held that plaintiff’s claim also had the requisite “connection with” motor vehicles because it arose out of a motor vehicle accident. The panel concluded that negligence claims against brokers, to the extent that they arise out of motor vehicle accidents, have the requisite “connection with” motor vehicles. Therefore, the safety exception applied to plaintiff’s claim against C.H. Robinson. Judge Fernandez concurred in parts I, II, and III A, B, C.1 of the majority opinion, and dissented from part C.2. Judge Fernandez would hold that plaintiff’s claim did not come within the safety exception of 49 U.S.C. § 1450(c)(2)(A) because as a broker, C.H. Robinson and the services it provided had no direct connection to motor vehicles or their drivers; and he would affirm the district court’s decision.