Transportation Law - Justia Case Law Summaries

Certain Underwriters at Lloyd's v CSX Transportation, Inc.

2026-06-25T09:31:27-08:00

National Railway Equipment sought to deliver four rebuilt locomotives from Illinois to North Carolina for export. The company’s logistics manager used online systems to contract with two rail carriers: Evansville Western Railway for the Illinois-to-Indiana leg, and CSX Transportation for the Indiana-to-North Carolina leg. For each shipment, the manager selected a standard transportation commodity code and accepted the carriers’ publicly available rates, which included liability limits per locomotive. The manager could have selected higher rates for greater carrier liability but opted not to, as National Railway Equipment carried its own insurance for losses. After the locomotives were destroyed in a derailment during Hurricane Florence while in CSX’s possession, the company’s insurer, Certain Underwriters at Lloyd’s, paid the claim and pursued reimbursement from the carriers under the Carmack Amendment. Evansville Western Railway moved for summary judgment, arguing liability was contractually capped, while CSX went to trial on similar terms. The United States District Court for the Southern District of Illinois found for Evansville Western on summary judgment, concluding the liability cap applied, and the jury found for CSX, also applying the contractual cap. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the carriers’ liability was properly limited under the Carmack Amendment. The court held that where a shipper knowingly selects a carrier’s rate that includes a liability cap, and the contractual documents (here, the bills of lading with the standard code) reflect this agreement, the limitation is enforceable—even if the cap is not stated verbatim in the bill of lading. The Seventh Circuit affirmed the district court’s summary judgment for Evansville Western and denial of judgment as a matter of law against CSX, upholding the application of the contractual liability limits. View "Certain Underwriters at Lloyd's v CSX Transportation, Inc." on Justia Law

Grafton & Upton Railroad Company v. Surface Transportation Board

2026-06-05T07:33:25-08:00

A railroad company operating in Massachusetts sought to acquire a 155-acre parcel in the town of Hopedale to build a new transloading facility. The land had been classified as forest land under Massachusetts General Law Chapter 61, which gives municipalities a right of first refusal to purchase such land if the owner wishes to sell or convert it to another use. After an initial notice of intent to sell was deemed deficient by the town, the seller withdrew the notice. Without issuing a new notice, the seller then transferred beneficial ownership of the property to the railroad company through a transaction that attempted to circumvent the town’s rights. Hopedale asserted its rights under Chapter 61 and filed suit in Massachusetts Land Court to enforce its right of first refusal and prevent further site work by the railroad. After a failed settlement agreement—subsequently invalidated by the Massachusetts Superior Court and with state litigation ongoing—the railroad company petitioned the Surface Transportation Board for a declaratory order that the Interstate Commerce Commission Termination Act (ICCTA) preempted the town’s rights under Chapter 61. The Surface Transportation Board denied the petition, finding that Chapter 61 was a generally applicable property law not categorically preempted by ICCTA, and that the railroad had not established a valid property interest in the land. The Board also concluded that the town’s actions did not unreasonably burden or interfere with rail transportation. The United States Court of Appeals for the District of Columbia Circuit reviewed the Board’s order. It held that ICCTA does not preempt Chapter 61’s right-of-first-refusal provisions, as they are generally applicable state property laws and do not directly regulate railroad operations. The court further found that, without a settled property interest, the railroad’s as-applied preemption arguments failed. The court denied the railroad’s petition for review and affirmed the Board’s order. View "Grafton & Upton Railroad Company v. Surface Transportation Board" on Justia Law

PEOPLE OF THE STATE OF CAL. V. FMCSA

2026-06-04T15:01:11-08:00

California officials challenged a determination by the Federal Motor Carrier Safety Administration (FMCSA) that California’s meal and rest break (MRB) rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted by federal law. The MRB rules require employers to provide drivers with specified meal and rest periods during the workday. The FMCSA concluded that these state rules regulated commercial motor vehicle safety, were more stringent than federal hours-of-service (HOS) regulations, and imposed requirements not found in federal law. Previously, in 2019, the American Bus Association petitioned the FMCSA to preempt California’s MRB rules for passenger-carrying drivers. After public notice and comment, the FMCSA issued a final order in 2020 preempting these rules, finding they added no measurable safety benefit beyond federal HOS rules, were incompatible with federal regulations, and placed an unreasonable burden on interstate commerce. California officials petitioned the United States Court of Appeals for the Ninth Circuit for review of the FMCSA’s preemption decision. The United States Court of Appeals for the Ninth Circuit reviewed the FMCSA’s action under the highly deferential standard of the Administrative Procedure Act. It held that its earlier decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021), foreclosed California’s main arguments and confirmed that the FMCSA had authority to preempt the MRB rules. The court also held that the FMCSA’s determination that the MRB rules imposed an unreasonable burden on interstate commerce was supported by the administrative record and not arbitrary or capricious. The petition for review was denied, and the FMCSA’s preemption determination was upheld. View "PEOPLE OF THE STATE OF CAL. V. FMCSA" on Justia Law

ModernWest Longmont, LLC v. FAA

2026-05-29T06:31:52-08:00

A property development company sought to build mixed-use housing developments near a public-use airport operated by the City of Longmont, Colorado. The proposed developments were located under the airport’s approach and departure paths. The company received preliminary approvals from the City for its projects and obtained “Determinations of No Hazard” from the Federal Aviation Administration (FAA), which found the developments would not obstruct flight paths. However, the FAA sent letters to the City warning that approving the developments would violate a grant assurance tied to the airport’s federal funding, specifically regarding land use compatibility. The City subsequently denied the company’s proposal, citing multiple reasons, including the FAA’s letters, concerns from state authorities, its own findings of incompatibility, and public opposition. After the City’s decision, the developer asked the FAA to withdraw its letters, but the FAA declined. The company then petitioned the United States Court of Appeals for the District of Columbia Circuit to order the FAA to vacate and withdraw these letters, arguing that the FAA’s actions directly caused its injury by influencing the City’s denial. The D.C. Circuit dismissed the petition for lack of standing. The court held that the developer failed to demonstrate that vacating the FAA’s letters would likely result in the City approving the developments, as the City had provided multiple independent reasons for its denial beyond the FAA’s communications. The court also found that the company did not comply with the court’s procedural rule requiring petitioners to argue and provide evidence of standing in their opening brief. Accordingly, the petition was dismissed. View "ModernWest Longmont, LLC v. FAA" on Justia Law

Declan Flight, Inc. v. Textron eAviation, Inc.

2026-05-26T10:04:34-08:00

Two American companies, Declan Flight, Inc. and Right Rudder Aviation, LLC (RRA), developed successful sales and distribution relationships with Pipistrel, a Slovenian aircraft manufacturer, through contracts signed in 2020 and 2021. Their contracts contained forum-selection clauses specifying Slovenia as the forum for disputes. In 2022, Textron, Inc., a large U.S. aerospace company, acquired Pipistrel through its subsidiary Textron eAviation, Inc. Shortly after the acquisition, Textron and eAviation orchestrated the termination of Declan’s and RRA’s contracts. RRA also lost a separate sales contract with Mesa Airlines after Textron and eAviation allegedly interfered with that business relationship. Declan and RRA sued Textron and eAviation in the United States District Court for the Middle District of Florida, alleging tortious interference with the Pipistrel contracts and with the Mesa Airlines contract. The district court dismissed the claims related to the Pipistrel contracts (Counts I and II) for forum non conveniens, holding that the forum-selection clauses could be enforced by Textron and eAviation—nonsignatories—under the federal doctrine of equitable estoppel, thus requiring litigation to proceed in Slovenia. The district court also found that personal jurisdiction existed for the Mesa Airlines claim (Count III), but dismissed it for failure to state a claim. On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the dismissal of Counts I and II. The court held that the applicability of the forum-selection clauses is governed by Slovenian law, not federal common law, and that Slovenian law does not permit nonsignatories to invoke these clauses. Thus, the district court erred in applying the modified forum non conveniens rule from Atlantic Marine. The Eleventh Circuit also reversed the finding of personal jurisdiction over Textron and eAviation as to Count III, remanding all claims for further proceedings. View "Declan Flight, Inc. v. Textron eAviation, Inc." on Justia Law

Beale v. Dept. of Motor Vehicles

2026-05-21T14:01:13-08:00

A man was stopped by police after riding an electric bicycle and showing signs of intoxication, including the odor of alcohol and bloodshot eyes. He refused to complete several sobriety tests and declined to provide a chemical sample when requested by the officer. The officer obtained a blood sample pursuant to a warrant, which revealed a blood alcohol level above the legal limit. The Department of Motor Vehicles (DMV) then suspended the man’s driver’s license for refusing a chemical test, treating his electric bicycle as a “motor vehicle” under the relevant Vehicle Code sections. The DMV held two administrative per se (APS) hearings to determine whether the license suspension was justified. At these hearings, the central dispute was whether the electric bicycle qualified as a “motor vehicle.” The hearing officer found that the bicycle was both a bicycle and a motor vehicle and upheld the license suspension. The man then filed a petition for writ of mandate in the Santa Clara County Superior Court, arguing that the statutory scheme did not authorize suspension for refusing a chemical test while riding an electric bicycle. The Superior Court denied the petition, concluding that bicyclists, regardless of the type of bicycle, are subject to the same rules as drivers of vehicles, including license suspension provisions. On appeal, the California Court of Appeal, Sixth Appellate District, independently reviewed the statutory scheme. The court held that under the Vehicle Code, an electric bicycle is not a “motor vehicle” for purposes of license suspension under section 13353, and the provisions authorizing suspension do not apply to electric bicycle riders. The appellate court reversed the judgment of the trial court and directed it to grant the petition for writ of mandate, thus rescinding the license suspension. The court did not reach the due process issue raised by the appellant. View "Beale v. Dept. of Motor Vehicles" on Justia Law

IN RE HOME DEPOT U.S.A., INC.

2026-05-15T06:11:30-08:00

A young man died after his motorcycle collided with a tractor-trailer owned and operated by a nationwide commercial motor carrier. The victim’s parents and his estate brought a wrongful-death and survival action against the trucking company, its driver, and a customer whose goods were being transported at the time of the accident. The plaintiffs alleged that the customer was negligent for hiring the trucking company, claiming it should have known the carrier employed reckless drivers due to a history of safety violations. However, the pleadings did not allege that the customer owned, operated, or controlled the truck, employed the driver, influenced how the shipment was conducted, or that the shipment itself involved any unusual risk or hazard. The trucking company and driver were sued for negligence and gross negligence. The plaintiffs later amended their petition to name the customer (a national retailer) as a defendant on the same theories. The customer moved to dismiss the claims under Texas Rule of Civil Procedure 91a, arguing it owed no duty of care to the public as a mere shipper of goods transported by an independent, federally regulated carrier. The trial court denied the motion to dismiss, and the Fourteenth Court of Appeals summarily denied mandamus relief. The Supreme Court of Texas reviewed the case on petition for writ of mandamus. It held that Texas law does not impose a duty of care on a passive shipper in these circumstances. The court concluded that because the customer neither created nor controlled the risk, and the allegations did not show any exception to the general rule against liability for acts of independent contractors, the claims against the customer had no basis in law. The Supreme Court of Texas conditionally granted mandamus relief, directing the trial court to vacate its denial and dismiss the claims against the customer. View "IN RE HOME DEPOT U.S.A., INC." on Justia Law

Arzu v. American Airlines

2026-05-14T15:30:30-08:00

A 14-year-old passenger, Kevin Greenidge, died from cardiac arrest aboard an American Airlines international flight from Honduras to Florida. Kevin, who suffered from multiple health conditions, began experiencing breathing difficulties soon after takeoff. Despite the crew’s efforts and the assistance of two medical professionals on board, Kevin did not survive. During the resuscitation attempt, there was a dispute about whether the aircraft’s automated external defibrillator (AED) functioned properly, as several witnesses reported it failed to deliver a shock, despite internal device data indicating otherwise. Following Kevin’s death, his aunt, Melissa Arzu, acting individually and as administrator of his estate, filed suit against American Airlines in the United States District Court for the Northern District of Texas. She alleged liability and loss of consortium under the Montreal Convention and breach of contract under Texas law. Both parties moved for summary judgment. The district court granted summary judgment in favor of American Airlines on all claims, finding that the alleged deviations from airline policy and medical response did not constitute an “accident” under Article 17 of the Montreal Convention. The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed summary judgment on the claims based on the crew’s allegedly ineffective medical response, holding that such a response does not amount to an “accident” under Article 17 without unusual circumstances or willful inaction. However, the court reversed summary judgment on the claims premised on the AED malfunction, finding that a genuine dispute remained as to whether the AED’s failure, in violation of FAA regulations, could be considered an “unexpected or unusual event.” The court also held that the Montreal Convention expressly preempts Arzu’s breach of contract claim. View "Arzu v. American Airlines" on Justia Law

Montgomery v. Caribe Transport II, LLC

2026-05-14T14:55:53-08:00

A man suffered severe injuries, including the loss of his leg, when his stopped tractor-trailer was struck by a truck driven by an employee of a motor carrier. The shipment had been coordinated by a broker, and the injured man alleged the broker was liable for negligently hiring the motor carrier and its driver, pointing to the carrier’s poor safety rating and regulatory violations. The claim asserted that the broker knew, or should have known, that hiring this carrier posed a reasonable risk of causing harm. In the United States District Court for the Southern District of Illinois, the broker moved to dismiss the negligent-hiring claim, arguing that it was preempted by the Federal Aviation Administration Authorization Act (FAAAA). That court, following precedent from the United States Court of Appeals for the Seventh Circuit, agreed and dismissed the claim, reasoning that it was expressly preempted by the FAAAA and did not fall within the safety exception. The Seventh Circuit affirmed the district court’s decision, maintaining that the safety exception did not apply to the broker in this context. The Supreme Court of the United States reviewed the case to resolve a division among the circuits. The Court held that the FAAAA’s safety exception does encompass negligent-hiring claims against brokers when those claims concern the use of motor vehicles in transportation. Specifically, the Court determined that state common-law negligent-hiring standards, as applied to brokers who select motor carriers, constitute the exercise of “safety regulatory authority of a State with respect to motor vehicles” and are thus not preempted by the FAAAA. The Supreme Court reversed the judgment of the Seventh Circuit and remanded the case for further proceedings. View "Montgomery v. Caribe Transport II, LLC" on Justia Law

MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC

2026-05-08T06:19:03-08:00

A company providing paratransit and microtransit services under contract with a regional public transportation authority subcontracted another company to supply vehicles and drivers. After several months, the subcontractor terminated the agreement and brought suit against the transportation company and the authority, asserting claims including breach of contract, quantum meruit, tortious interference, fraud, and negligent misrepresentation. The fraud claim centered on alleged false representations made to induce the subcontract. The trial court (Texas District Court) ruled on a motion to dismiss under Texas Rule of Civil Procedure 91a, which allows dismissal if pleadings show no legal or factual basis for relief. The court dismissed the fraud and other tort claims against all defendants, as well as the breach of contract claim against the transportation authority and its primary contractor. It limited potential contract damages as to the contractor’s subsidiary and severed and abated remaining claims. The subcontractor appealed the dismissal of its claims against the main transportation company. The Court of Appeals for the Fifth District of Texas reversed in part, finding that the breach of contract and fraud claims against the main transportation company had a basis in law and that its statutory immunity under Texas Transportation Code § 452.056(d) was not conclusively established. The Supreme Court of Texas, reviewing only the fraud claim, held that the statutory immunity did apply. Because the pleadings showed the transportation company was contractually performing the authority’s function, and the authority itself would be immune from a fraud claim (an intentional tort), the company was likewise immune from liability for fraud. Accordingly, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s dismissal of the fraud claim. The case was remanded for further proceedings on any remaining claims. View "MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC" on Justia Law

IN RE BELL HELICOPTER SERVICES INC.

2026-04-24T06:22:48-08:00

A helicopter manufactured in 1997 by Bell Helicopter Textron Inc. was involved in a fatal crash in 2017 after an engine cowling came loose and struck the tail rotor. The pilot, working for a later owner, died in the accident. The pilot’s family brought suit against Bell, alleging that the flight manual was defective for failing to include an explicit warning about the dangers of flying with an unsecured engine cowling, even though the manual included a checklist item stating the cowling should be “Secured.” The physical cowling and its fasteners were original to the aircraft and had not been replaced or modified. Bell asserted that the General Aviation Revitalization Act of 1994 (GARA), an 18-year statute of repose, barred the suit. The plaintiffs responded that the repose period had been reset because Bell periodically revised the flight manual in the years before the crash. The 270th District Court of Harris County denied Bell’s summary judgment motion without explanation. Bell then sought mandamus relief from the Fourteenth Court of Appeals, which denied the petition without a substantive opinion. The Supreme Court of Texas held that GARA’s 18-year clock is only reset when a “new” part or component, including a substantive revision to the flight manual, is added or replaced and is alleged to have caused the accident. Because the engine-cowling instruction in the manual, which was the alleged defect, had not been revised since 1997, and no relevant “new” part was implicated, the rolling provision of GARA did not apply. The court conditionally granted Bell’s petition for writ of mandamus and directed the district court to grant summary judgment for Bell, holding that GARA bars the suit and that mandamus relief was appropriate to prevent litigation Congress has expressly foreclosed. View "IN RE BELL HELICOPTER SERVICES INC." on Justia Law

MCAULIFFE V. ROBINSON HELICOPTER COMPANY

2026-04-21T08:31:41-08:00

The case concerns a fatal helicopter crash during a sightseeing tour in Hawaii, resulting in the deaths of all aboard, including the plaintiffs’ daughter. The helicopter, manufactured by Robinson Helicopter Company in 2000, had its main rotor hub and blades replaced with new, identical parts from Robinson in December 2018, which was over eighteen years after the helicopter’s initial delivery. The plaintiffs alleged that defects in the replaced rotor hub and blades caused the crash, and brought claims for negligence, strict products liability, and failure to warn. The United States District Court for the District of Hawaii heard the case first. Robinson invoked the General Aviation Revitalization Act of 1994 (GARA), which generally bars actions against manufacturers eighteen years after delivery of the aircraft. The plaintiffs argued for exceptions under GARA’s “rolling provision”—which restarts the repose period for newly replaced parts—and the “fraud exception”—which removes the bar if the manufacturer concealed or misrepresented material information to the FAA. The district court granted summary judgment for Robinson, holding that the rolling provision did not apply because the replacement parts were not substantively altered from the originals, and that the plaintiffs failed to plead fraud with the necessary specificity. The court also denied the plaintiffs’ motion to further amend their complaint. On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court erred in requiring a “substantive alteration” for the rolling provision to apply, as GARA only requires that a new part replaces an old one. The Ninth Circuit reversed the grant of summary judgment in part and remanded for a new causation analysis regarding the replaced parts. However, the court affirmed the lower court’s determinations that the plaintiffs failed to meet the requirements for the fraud exception and that denying leave to amend was not an abuse of discretion. View "MCAULIFFE V. ROBINSON HELICOPTER COMPANY" on Justia Law

Fisher v. Town of Hampden

2026-04-16T07:04:24-08:00

A woman was struck and injured by a bus in Bangor, Maine. The bus was operated as part of a public transit system known as the Community Connector, which serves several municipalities and the University of Maine. The City of Bangor oversees daily operations of the Community Connector, but the precise extent of involvement by the neighboring towns and cities is disputed. It is also unclear whether the bus that struck the plaintiff was running on a Community Connector route or a Bangor-only route; the buses for both services look the same. The plaintiff filed a complaint in the Penobscot County Superior Court against the City of Bangor, the Community Connector, and several neighboring towns and cities, alleging negligence and asserting that the Community Connector operated as a joint venture among the defendants. The municipalities moved for summary judgment, arguing they were immune from suit under the Maine Tort Claims Act. The Superior Court denied summary judgment, holding that the municipalities had not established that there were no material disputes of fact regarding their involvement or possible joint venture status. The court also denied a motion for reconsideration. On appeal, the Maine Supreme Judicial Court considered whether the municipalities were entitled to immunity as a matter of law. The Court found that key factual questions remained unresolved, including whether the municipalities exercised direct control over the bus or its driver and the nature of their participation in the Community Connector. Because these factual disputes must be resolved by the trial court before determining the applicability of immunity, the Maine Supreme Judicial Court dismissed the appeal as interlocutory, leaving the issue of immunity to be addressed after further factual development in the trial court. View "Fisher v. Town of Hampden" on Justia Law

Khalid v. TSA

2026-04-14T06:56:32-08:00

A United States citizen of Pakistani descent challenged his continued placement on the federal No Fly List, which prohibits individuals from boarding flights in U.S. airspace. After enhanced screening and questioning by the FBI in 2012 and being prevented from boarding a flight in 2019, he sought redress through the Department of Homeland Security Traveler Redress Inquiry Program (DHS TRIP). He received an unclassified summary stating that his listing was based on concerns about his associations and candor regarding activities in Pakistan. He contested these grounds, denied any terrorist associations, and argued that his inclusion was erroneous. While his DHS TRIP redress was pending, he filed suit in the United States District Court, which ultimately concluded it lacked jurisdiction, as exclusive review of the Transportation Security Administration (TSA) Administrator’s order rested with the United States Court of Appeals for the District of Columbia Circuit. The district court transferred his claims to the appellate court. The United States Court of Appeals for the District of Columbia Circuit reviewed the TSA Administrator’s order, applying a “substantial evidence” and “arbitrary and capricious” standard, and reviewed constitutional claims de novo. The court dismissed the petitioner’s Religious Freedom Restoration Act claim for lack of standing, finding insufficient concrete plans to travel for religious purposes. It denied his other claims, holding that there is no fundamental right to air travel under substantive due process, and that the DHS TRIP process provides constitutionally adequate procedural protections. The court found that the Administrator’s order was supported by substantial evidence and not arbitrary or capricious. The court also rejected the argument that the major questions doctrine applied, finding TSA’s statutory authority adequate. The petition was dismissed in part and otherwise denied. View "Khalid v. TSA" on Justia Law

Cupp v. Delta Air Lines, Inc.

2026-04-02T05:25:29-08:00

A man traveling with his family, including his thirteen-year-old daughter, on Delta Air Lines was reported by a flight attendant for suspected human trafficking or sexual abuse after comforting his distressed daughter during turbulence. The flight attendant relayed her suspicions to the flight captain, who then involved the airport station manager, resulting in a call to law enforcement. Upon landing, police detained and questioned the man and his daughter but found no probable cause for arrest. The incident caused the man significant emotional distress and exacerbated his pre-existing PTSD. He subsequently filed a lawsuit in the Circuit Court of the City of Newport News against the flight attendant, Delta, and Endeavor Air, alleging negligence, intentional infliction of emotional distress, tortious interference with parental rights, and false imprisonment. The defendants removed the case to the United States District Court for the Eastern District of Virginia and moved to dismiss, claiming immunity under Virginia Code § 63.2-1512. The district court agreed, holding that the defendants were immune because the report, even if made only to law enforcement and not to social services, was made in good faith and without malicious intent. The man appealed, and the United States Court of Appeals for the Fourth Circuit was uncertain whether the immunity statute applied in this context and certified the legal question to the Supreme Court of Virginia. The Supreme Court of Virginia, upon review of the certified question, held that Virginia Code § 63.2-1512 does not provide immunity to a nonmandatory reporter who, in good faith, reports suspected child abuse to law enforcement without also contacting a Department of Social Services employee or the designated hotline. The Court reasoned that the statutory language is clear and limits immunity to specific categories, which do not include complaints made solely to law enforcement by nonmandatory reporters. The answer to the certified question was “no.” View "Cupp v. Delta Air Lines, Inc." on Justia Law

In re Ryan

2026-03-31T10:02:38-08:00

Following two fatal airplane crashes involving Boeing 737 MAX aircraft in 2018 and 2019, which resulted in significant loss of life, the Department of Justice investigated Boeing for misleading the Federal Aviation Administration about changes to flight control systems. The Department initially entered into a Deferred Prosecution Agreement (DPA) with Boeing, requiring the company to pay a substantial fine and undertake remedial measures. After Boeing was alleged to have breached the DPA, the Department negotiated a Non-Prosecution Agreement (NPA) in 2025, again requiring compliance and penalties. Family members of crash victims challenged both the DPA and NPA, asserting violations of their rights under the Crime Victims’ Rights Act (CVRA). The families first moved in the United States District Court for the Northern District of Texas to set aside the DPA, arguing they were denied timely notice and the right to confer as crime victims. The district court found the Department had not acted in bad faith but had committed a legal error in initially failing to recognize the families as crime victims. The court concluded, however, that it lacked authority to review or alter the terms of the DPA. When the Department later moved to dismiss the charges based on the NPA, the families objected, but the district court granted the motion, finding the Department had provided sufficient reasons and had not acted with bad faith. The families petitioned the United States Court of Appeals for the Fifth Circuit for writs of mandamus. The Fifth Circuit held that the challenge to the DPA was moot because it was no longer in effect after Boeing’s breach. As to the NPA, the court found the Department had satisfied the CVRA’s requirements to confer with and treat the families fairly. The court also ruled it lacked jurisdiction under the CVRA to conduct a substantive review of the district court’s dismissal of charges. The petitions for writ of mandamus were denied. View "In re Ryan" on Justia Law

Hardwick v. FAA

2026-03-23T10:01:24-08:00

A professional pilot was asked to operate a Cessna Citation 550 aircraft whose tail number had recently been changed by its owner from N550ME to N550MK. The Federal Aviation Administration (FAA) approved the new registration and issued new documents, but denied a new airworthiness certificate because the aircraft required further inspection. Believing the registration had reverted to the old number due to the denial, the owner had the physical tail number altered back to N550ME using tape, while the aircraft carried documents for both the old and new registrations. The pilot, after being told about “paperwork issues” and noticing the taped number, proceeded to fly the aircraft on two flights without confirming the correct registration and without a valid airworthiness certificate for the current registered tail number. After the first flight, FAA inspectors issued a written notice warning that further operation would violate federal regulations; the pilot disregarded this and completed the return flight. The FAA suspended the pilot’s license for 150 days, citing violations of various regulations requiring proper display of the registered tail number and possession of a valid airworthiness certificate. The pilot appealed the suspension to the National Transportation Safety Board (NTSB), where an Administrative Law Judge affirmed the FAA’s order after a hearing. The full NTSB then affirmed the ALJ’s decision. The United States Court of Appeals for the Fifth Circuit reviewed the case, applying a deferential standard to the agency’s findings and sanction. The court held that the NTSB’s decision was not arbitrary or capricious. The court concluded that the pilot’s reliance on the owner’s explanation was unreasonable and that the penalty was not excessive, even if the violations were administrative. The court also found no improper disparity in sanctioning compared to another pilot. The petition for review was denied, and the suspension was upheld. View "Hardwick v. FAA" on Justia Law

Byrd v. Avco Corp

2026-03-20T07:36:26-08:00

Several individuals died in a 2015 small aircraft accident in Georgia, including the pilot and three passengers. The plaintiffs, representing the victims and their estates, brought claims in 2017 against Avco Corporation and its division, Lycoming Engines, which manufactured the aircraft’s engine, as well as against companies that performed maintenance on the engine. The claims included strict liability, negligence, fraud, breach of warranties, and other theories. Over time, all defendants except Avco were voluntarily dismissed from the suit. The Superior Court in Buncombe County was assigned the case as exceptional. In 2022, the court granted Avco summary judgment on all claims except negligent failure to warn, finding a genuine issue of material fact as to whether Avco had misrepresented or withheld information from the Federal Aviation Administration, which could trigger an exception to the statute of repose under the General Aviation Revitalization Act of 1994 (GARA). Avco moved for reconsideration, which the trial court denied in 2024, reaffirming that the question of whether Avco knowingly concealed required information should go to the jury. Avco appealed this interlocutory order to the North Carolina Court of Appeals. The Court of Appeals dismissed the appeal, presumably for lack of appellate jurisdiction over an interlocutory order. Avco then sought review in the Supreme Court of North Carolina. The Supreme Court of North Carolina held that the Court of Appeals erred in dismissing the appeal. The Supreme Court clarified that an interlocutory order denying a statute of repose defense, such as GARA, affects a substantial right because it grants immunity from suit—not merely from liability—and thus is immediately appealable. The Court overruled contrary Court of Appeals precedent and reversed and remanded for the Court of Appeals to address the merits of Avco’s claim to statutory immunity. View "Byrd v. Avco Corp" on Justia Law

Galette v. New Jersey Transit Corp.

2026-03-04T07:45:05-08:00

The case concerns injuries suffered by two individuals, one in New York and one in Pennsylvania, each struck by buses operated by New Jersey Transit Corporation (NJ Transit), a public transportation entity created by the New Jersey Legislature. NJ Transit operates as a “body corporate and politic” with significant powers such as suing and being sued, entering contracts, and raising funds. Its founding statute specifies that debts or liabilities of NJ Transit are not debts of the State of New Jersey, and all expenses must be paid from NJ Transit’s own funds. The State retains substantial control over NJ Transit through board appointments and removal powers, veto authority, and some legislative oversight, but the statute also stresses NJ Transit’s operational independence. After the incidents, the injured parties filed negligence lawsuits against NJ Transit in their home state courts. NJ Transit moved to dismiss both suits, arguing it was an arm of New Jersey and thus entitled to sovereign immunity. The Court of Appeals of New York concluded that NJ Transit is not an arm of New Jersey, allowing the New York suit to proceed. Conversely, the Supreme Court of Pennsylvania found that NJ Transit is an arm of New Jersey and dismissed the Pennsylvania suit. The Supreme Court of the United States reviewed both cases to resolve the conflict. It held that NJ Transit is not an arm of the State of New Jersey and therefore does not share in New Jersey’s interstate sovereign immunity. The Court emphasized that NJ Transit’s status as a legally separate corporation, responsible for its own debts and judgments, and the absence of formal state liability for its obligations, are decisive. The Court affirmed the New York decision, reversed the Pennsylvania decision, and remanded both cases for further proceedings. View "Galette v. New Jersey Transit Corp." on Justia Law

Adams v. FAA

2026-03-03T09:02:30-08:00

A commercial air tour operator, who had previously conducted flights over Bandelier National Monument under interim authority, challenged a final order issued by the Federal Aviation Administration and the National Park Service. This order established an Air Tour Management Plan (ATMP) for Bandelier National Monument, prohibiting all commercial air tours over the site. The agencies’ process included public comment, environmental assessment, and extensive consultation with Native American tribes, who strongly objected to air tours due to cultural and privacy concerns. The operator argued that his flights were minimally intrusive, carefully routed, and brief, and that banning them would negatively impact safety and his business. The agencies initially considered various alternatives, including allowing limited air tours or maintaining previous operations, but ultimately concluded that any commercial air tour flights would create unacceptable impacts to Bandelier’s natural and cultural resources and visitor experience. The agencies’ environmental assessment under the National Environmental Policy Act (NEPA) found no significant impacts for NEPA purposes, but their record of decision emphasized significant adverse impacts to tribal cultural resources under the National Parks Air Tour Management Act (NPATMA). Upon petition for review, the United States Court of Appeals for the Tenth Circuit reviewed the agency action under the Administrative Procedure Act’s “arbitrary and capricious” standard and de novo for statutory interpretation, as required by recent Supreme Court precedent. The court held that NPATMA and NEPA use different significance standards, and that the agency’s path to finding significant adverse impacts under NPATMA was reasonably discernible in the record. The court also rejected the petitioner’s additional statutory and constitutional challenges, finding them either unexhausted or inadequately briefed. The Tenth Circuit denied the petition for review. View "Adams v. FAA" on Justia Law

Paul v. FAA

2026-02-27T07:34:59-08:00

A pilot employed by a cargo airline was on a personal trip abroad when his employer, Amerijet International, selected him for a random drug test and requested that he appear for testing in Seattle on the same day. The pilot was unable to comply due to his location and a medical issue. The airline determined that he had refused the test, reported this to the Federal Aviation Administration (FAA), and subsequently terminated his employment. The FAA corresponded with the pilot, initially investigating the matter and ultimately informing him that, while it was not taking enforcement action against his certificates, he would be subject to return-to-duty requirements because of the refusal determination, and the test refusal would be reported to the Pilot Records Database. The pilot challenged these consequences, arguing that the FAA had not independently reviewed the employer’s determination that he refused the test. The FAA responded that test-refusal determinations were made solely by the employer, not by the agency, and that the FAA did not review such determinations. The case came before the United States Court of Appeals for the District of Columbia Circuit on the pilot’s petition for review of the FAA’s actions. The Court of Appeals held that the FAA’s internal guidance, specifically its Drug and Alcohol Compliance and Enforcement Surveillance Handbook, plausibly requires the FAA to independently review an employer’s test-refusal determination. The court interpreted the Handbook to require such review, partly to avoid serious constitutional concerns that would arise if the FAA entirely delegated this authority to private employers without oversight. Because the FAA conceded that it did not conduct any review, the court found the agency’s actions to be arbitrary and capricious for departing from its own procedures. The court granted the petition in part, remanding the case to the FAA for further review consistent with its opinion. View "Paul v. FAA" on Justia Law

Wells v. BNSF Railway Co.

2026-02-24T09:31:18-08:00

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period. This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

Hamer V. Duffy

2026-02-05T08:17:59-08:00

A plaintiff was injured in a collision at an intersection controlled by a malfunctioning traffic signal. Both drivers claimed to have stopped at the flashing red light and to have the right of way. The defendant was driving a truck for his employer, who was also named in the suit under the doctrine of respondeat superior. The plaintiff alleged negligence by the truck driver in failing to maintain control, keep a proper lookout, and yield, and sought damages for injuries and loss of consortium. The employer denied negligence and asserted contributory negligence by the plaintiff. The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, granted the employer’s motion to exclude two of the plaintiff’s expert witnesses, finding their testimony would not aid the jury. The court also denied the plaintiff’s motion to amend the complaint shortly before trial, which sought to add direct negligence claims against the employer and violations of Federal Motor Carrier Safety Regulations (FMCSRs). Additionally, the court refused a jury instruction on those regulations. At trial, the jury found the defendant negligent but determined the plaintiff was contributorily negligent to a degree greater than slight, awarding no damages. The Supreme Court of the State of South Dakota reviewed the appeal. It held that the circuit court did not abuse its discretion in denying the motion to amend as to direct negligence claims against the employer due to untimeliness and prejudice, but erred in denying amendment as to the truck driver’s alleged FMCSR violations, since those allegations provided statutory grounds for existing negligence claims and were not prejudicial or futile. The Supreme Court also held that excluding the expert testimony was an abuse of discretion, as it would have assisted the jury, and that refusal to instruct the jury on FMCSRs was erroneous. The judgment was affirmed in part and reversed in part. View "Hamer V. Duffy" on Justia Law

Tavares v. Zipcar, Inc.

2026-01-30T10:31:49-08:00

A passenger was seriously injured after the driver of a remotely rented vehicle, accessed via a membership-based car-sharing service, crashed while under the influence of alcohol. The driver, a university student and approved member of the rental service, reserved the vehicle through a mobile app late at night after consuming alcohol at a party. The process for renting and accessing the car involved no face-to-face interaction with company staff, and the company had no prior knowledge of the driver’s intoxication or any history of impaired driving. Following the crash, the driver was convicted of felony DUI causing injury. The injured passenger sued the car-sharing company and its affiliated vehicle owner in the Superior Court of Yolo County, alleging negligent entrustment for providing the car to an unfit driver, negligent maintenance for failing to include technology to detect driver impairment, and vicarious liability based on vehicle ownership. Both sides moved for summary judgment. The trial court ruled for the defendants, holding that the company owed no duty to inquire about a renter’s impairment at the time of a remote rental, had no duty to install alcohol-detection devices, and was shielded from vicarious liability by federal law (the Graves Amendment). On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The court held that remote rental car companies are exempt from statutory requirements to inspect for signs of impairment at the time of rental, per Civil Code section 1939.37, and that courts should not impose additional investigatory duties absent legislative action. The court also held that the Graves Amendment preempts state law claims of vicarious liability based solely on vehicle ownership. Judgment for the defendants was therefore affirmed. View "Tavares v. Zipcar, Inc." on Justia Law

Spokane Airport Board v. TSA

2026-01-20T07:30:46-08:00

This case concerns the Transportation Security Administration’s issuance of an emergency amendment that required certain airport operators to incorporate specific cybersecurity measures and controls into their airport security programs. The amendment, issued in March 2023, responded to increasing cyber threats to the aviation sector, including ransomware and foreign cyberattacks. Under the amendment, airports were required to identify critical systems, submit a cybersecurity implementation plan, and assess their effectiveness annually. The Spokane Airport Board, which operates Spokane International Airport, objected to the amendment on both procedural and substantive grounds. After the amendment was issued, the Spokane Airport Board petitioned the TSA for reconsideration, raising various objections. The TSA denied these petitions, upholding the emergency amendment. Spokane then filed a timely petition for review with the United States Court of Appeals for the District of Columbia Circuit, as provided by statute. The United States Court of Appeals for the District of Columbia Circuit reviewed the TSA’s order under the standards of the Administrative Procedure Act, specifically considering whether it was arbitrary, capricious, or contrary to law. The court held that it lacked jurisdiction to review arguments not properly raised before the TSA, as required by statute. The court found that the objections Spokane did properly exhaust were meritless. It concluded that the TSA possesses broad statutory authority to regulate aviation security—including cybersecurity—in response to threats. The court also found that the emergency amendment was consistent with TSA regulations and was not arbitrary or capricious. Accordingly, the court denied Spokane’s petition for review, leaving the TSA’s emergency cybersecurity amendment in effect. View "Spokane Airport Board v. TSA" on Justia Law

Hu v. XPO Logistics, LLC

2026-01-16T15:31:48-08:00

On a rainy night in March 2020, the plaintiff was catastrophically injured while sleeping in a truck driven by his co-worker, both of whom were transporting plasticware from New Jersey to California. The truck, owned and operated by Alliance, a federally licensed motor carrier, crashed on a highway near Oklahoma City. The transportation had been arranged by XPO Logistics, LLC, a federally licensed property broker, which was hired by Sabert Corporation to facilitate shipping but did not own trucks or employ drivers. XPO contracted with Alliance to perform the transport, and Alliance assigned the plaintiff and his co-worker to drive the shipment. After the accident, the plaintiff sued XPO in the Superior Court of Los Angeles County, alleging negligence based on claims that XPO exercised control over the transport and owed a nondelegable duty to maintain a safe workplace. XPO moved for summary judgment, arguing it was solely a broker and not responsible for the carrier’s employee safety. The trial court granted summary judgment for XPO, finding the evidence undisputed that XPO acted as a broker, not a carrier, and did not control Alliance’s transport operations. The trial court also excluded plaintiff’s expert declaration, which had applied the wrong legal standard. The California Court of Appeal, Second Appellate District, reviewed the judgment. The court held that under California law, a broker who hires an independent contractor carrier generally owes no duty of care to the carrier’s employees for workplace injuries, unless the broker has a nondelegable duty or retains and exercises control over the work. The court found no triable issues of fact supporting either exception, and further clarified that the federal Essex Insurance Company v. Barrett Moving & Storage, Inc. test for broker liability for cargo damage is irrelevant to personal injury claims under California law. The judgment for XPO was affirmed. View "Hu v. XPO Logistics, LLC" on Justia Law

Mendocino Railway v. Meyer

2026-01-07T10:01:36-08:00

Mendocino Railway, a California railroad corporation, sought to acquire a 20-acre parcel in Willits, California owned by John Meyer through eminent domain. The property is adjacent to Mendocino Railway’s tracks and was intended for the construction and maintenance of rail facilities supporting ongoing and future freight and passenger operations. The company argued that, as a common carrier public utility under relevant statutes, it had the authority to exercise eminent domain for public use. The evidence at trial included testimony about the history of rail service on the line, Mendocino Railway’s acquisition and operations, including passenger excursions and more limited commuter and freight services, and the necessity of the property for expanding its rail facilities. The Mendocino County Superior Court conducted a bench trial and found that Mendocino Railway failed to qualify as a public utility entitled to exercise eminent domain. The court reasoned that the railway’s primary activity was excursion service, which does not confer public utility status, and was unconvinced by the evidence of passenger and freight services. The court further concluded that, even if Mendocino Railway had public utility status, it did not meet the statutory requirements for eminent domain, finding the primary purpose of the proposed taking to be for private business activities rather than public use. The court also found insufficient evidence regarding the project’s impacts on neighboring residents and questioned the credibility and timing of Mendocino Railway’s site plans. On appeal, the California Court of Appeal, First Appellate District, Division One, reversed the trial court’s judgment. The appellate court held that Mendocino Railway met its burden of proving it was a common carrier public utility under California law, and that it satisfied the statutory requirements for eminent domain: public interest and necessity, proper planning for public good and least private injury, and necessity of the property for the project. The court remanded the case for further proceedings regarding compensation to Meyer. View "Mendocino Railway v. Meyer" on Justia Law

Aaron v. National Railroad Passenger Corporation

2025-12-31T08:30:22-08:00

The dispute arose from a tragic incident on January 14, 2022, when Marquise Webb and Richie Aaron, Jr. boarded an Amtrak train in Illinois. Although unrelated, both transferred to Amtrak’s River Runner train in Missouri, where Webb fatally shot Aaron without apparent motive during a scheduled stop. Amtrak prohibits firearms onboard, but does not routinely conduct passenger security screenings. After the shooting, Amtrak crew initially dismissed reports of gunfire as fireworks, and medical aid was rendered to Aaron at the next station, but he was pronounced dead shortly thereafter. Following these events, Breayonna Aaron, representing herself, her deceased husband, and their children, filed suit in the United States District Court for the Western District of Missouri against Amtrak for negligence, negligent hiring/training/supervision, and wrongful death, seeking substantial compensatory and punitive damages. Amtrak moved for judgment as a matter of law, but the court submitted the case to a jury, which found Amtrak liable and awarded both compensatory and punitive damages. After trial, Amtrak renewed its motion for judgment as a matter of law or, alternatively, sought a new trial or reduction in punitive damages. The district court denied Amtrak’s motions, but reduced the punitive damages award as constitutionally excessive. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of Amtrak’s motion for judgment as a matter of law de novo. It held that the plaintiffs failed to provide legally sufficient evidence of a duty or causation under any negligence theory presented, as Missouri law requires foreseeability of criminal acts for a duty to exist, and but-for causation for wrongful death. The appellate court reversed the district court’s denial of Amtrak’s motion for judgment as a matter of law and directed the entry of judgment for Amtrak, finding no basis for liability on the claims asserted. View "Aaron v. National Railroad Passenger Corporation" on Justia Law

Noland v. State

2025-12-23T14:36:01-08:00

Parker Noland operated a construction debris removal business in Flathead County, Montana, but was ordered by the Montana Public Service Commission to cease operations due to lacking a required Class D motor carrier certificate. Noland formed PBN LLC and applied for the certificate, but withdrew his application after finding the administrative process—including requests for sensitive financial information by competitors—too burdensome. He then limited his business to activities not requiring the certificate. Subsequently, Noland filed suit in the Eleventh Judicial District Court of Flathead County, seeking a declaratory judgment that two provisions of the Montana Motor Carrier law, known as the public convenience and necessity (PCN) provisions, were unconstitutional under both the Montana and United States Constitutions. The District Court granted summary judgment in favor of the State of Montana and Evergreen Disposal, Inc., which had intervened. The court held that Noland lacked standing to bring an as-applied constitutional challenge, reasoning he sought to vindicate only a future injury and had not shown how the statutes would be unconstitutionally applied to him. However, the court found Noland had standing to bring a facial challenge, but ruled against him, concluding the provisions were not facially unconstitutional because some applicants had previously received Class D certificates. On appeal, the Supreme Court of the State of Montana reviewed the District Court’s rulings de novo. The Montana Supreme Court affirmed the District Court’s decision that Noland lacked standing for an as-applied challenge, holding that he failed to demonstrate a concrete injury or how the statutes were applied to him. The Court reversed the District Court’s denial of Noland’s facial challenge, holding that he had standing to challenge the statute’s constitutionality on its face, since the procedural requirements themselves could constitute injury regardless of outcome. The case was remanded for further consideration of the facial constitutional challenges. View "Noland v. State" on Justia Law

Panting v. United States

2025-12-22T08:30:21-08:00

Ronald B. Panting, an independent contractor serving as a Designated Pilot Examiner (DPE) for the FAA, was conducting a pilot certification checkride for Michael Trubilla in a plane rented from the LeMay Aero Club, a government-affiliated organization. Both men died when the plane crashed during the checkride. Five days prior to the accident, Ronald signed a covenant not to sue the government for injuries sustained while participating in Aero Club activities, applicable to himself and his estate. His spouse, Lynne D. Panting, sued the United States under the Federal Tort Claims Act, alleging negligent maintenance of the aircraft. The United States District Court for the District of Nebraska denied the government’s motion for summary judgment, ruling the covenant not to sue was void as against public policy under Nebraska law. The court did not address Lynne’s alternative argument that the covenant did not apply to Ronald’s activities as a DPE on the day of the crash. Following a bench trial, the district court found the government negligent and entered judgment for Lynne, awarding damages. The government appealed, challenging the district court’s decision regarding the covenant’s validity. The United States Court of Appeals for the Eighth Circuit held that it had jurisdiction to review the denial of summary judgment because the enforceability of the covenant was a purely legal issue. Applying Nebraska law, the appellate court determined the covenant was neither clearly repugnant to public policy nor the product of disparate bargaining power, and that the Aero Club did not provide a public or essential service. The Eighth Circuit reversed the district court’s judgment and remanded for consideration of whether the covenant covered Ronald’s activities as a DPE, and for further proceedings as appropriate. View "Panting v. United States" on Justia Law

Iowa Northern Railway Company v. Floyd County Board of Supervisors

2025-12-19T07:04:09-08:00

A joint drainage district, managed by the boards of supervisors for Floyd and Cerro Gordo Counties, sought to require a railroad company to install a new, larger drainage culvert through a railroad embankment to improve water flow and address aging infrastructure. The existing culvert, over a century old, was deteriorating and positioned too high to drain water effectively. The proposed construction involved a trenchless “jack and bore” method designed to avoid any interruption to rail service. The railroad company objected, arguing that federal law preempted state drainage law and that the construction would jeopardize railroad operations. After a remand from the Surface Transportation Board, the Iowa District Court for Floyd County conducted a bench trial and concluded that federal law—the Interstate Commerce Commission Termination Act—preempted the drainage district’s authority. The district court found that the proposed installation posed risks to rail operations and issued a writ of mandamus preventing the project. The Iowa Court of Appeals affirmed this decision. On further review, the Iowa Supreme Court held that the federal statute did not categorically preempt state drainage law in this context and that preemption would only apply if the project imposed more than incidental interference with rail operations. After a de novo review of the evidence, the court determined that the proposed culvert installation would have only incidental effects on rail transportation and that the railroad had not met its burden of showing unreasonable interference. The Iowa Supreme Court vacated the Court of Appeals’ decision, reversed the district court’s judgment, and remanded the case for entry of judgment in favor of the drainage district, dissolving the writ of mandamus. View "Iowa Northern Railway Company v. Floyd County Board of Supervisors" on Justia Law

THIRD COAST SERVICES, LLC v. CASTANEDA

2025-12-12T07:14:56-08:00

Pedro Castaneda died in a traffic accident at an intersection on State Highway 249 that was under construction. At the time, the intersection’s traffic lights were installed but not yet operational, and there was a dispute about whether they were properly covered to indicate their status. Castaneda’s family sued the contractors involved in the project, SpawGlass Civil Construction, Inc. and Third Coast Services, LLC, alleging that negligence in the construction and installation of the traffic signals contributed to the fatal accident. The construction project was governed by an agreement between the Texas Department of Transportation (TxDOT) and Montgomery County, with the County responsible for the project’s design and construction, but with TxDOT retaining authority over the adjacent frontage roads and final approval of plans. The trial court denied the contractors’ motions for summary judgment that sought dismissal under Texas Civil Practice and Remedies Code Section 97.002, which grants immunity to contractors under certain conditions. The contractors appealed. The Fourteenth Court of Appeals affirmed, concluding that Section 97.002 applies only to contractors who are in direct contractual privity with TxDOT, and since neither contractor had a direct contract with TxDOT, they could not invoke the statute’s protection. The Supreme Court of Texas reversed the court of appeals. It held that Section 97.002 does not require direct contractual privity with TxDOT for a contractor to qualify for statutory immunity. The court determined that, based on the summary judgment record, SpawGlass and Third Coast performed work "for" TxDOT within the meaning of the statute, as their activities directly related to frontage roads that TxDOT would own and maintain. The court remanded the case to the court of appeals to determine whether the contractors met the remaining requirements of Section 97.002. View "THIRD COAST SERVICES, LLC v. CASTANEDA" on Justia Law

Southern Airways Express, LLC v. DOT

2025-11-14T08:00:49-08:00

A commuter airline that had provided federally subsidized air service to a small community in West Virginia for several years sought to continue serving that community under the Essential Air Service (EAS) program. In 2024, the U.S. Department of Transportation (DOT) solicited bids for a new three-year EAS contract. Four airlines, including the incumbent, submitted proposals. The DOT evaluated the applications based on five statutory factors: reliability, agreements with larger carriers, community preferences, marketing plans, and total compensation requested. After reviewing the proposals and soliciting input from the local community, which favored a different airline, the DOT selected a new carrier that offered larger aircraft, a codeshare agreement with a major airline, and a subsidy request within the competitive range. The incumbent airline challenged the DOT’s selection in the United States Court of Appeals for the District of Columbia Circuit, arguing that the agency’s decision was arbitrary and capricious, unsupported by substantial evidence, and exceeded its statutory authority. The petitioner contended that the DOT failed to meaningfully analyze the statutory factors and improperly chose a more expensive proposal. The United States Court of Appeals for the District of Columbia Circuit held that it had jurisdiction to review the DOT’s order under 49 U.S.C. § 46110(a). On the merits, the court found that the DOT’s findings regarding each statutory factor were supported by substantial evidence and that the agency’s reasoning was adequately explained. The court concluded that the DOT’s selection process was reasonable, not arbitrary or capricious, and that the agency did not exceed its statutory authority. Accordingly, the court denied the petition for review and upheld the DOT’s selection of the new EAS carrier. View "Southern Airways Express, LLC v. DOT" on Justia Law

U.S. Specialty Ins. Co. v. D S Avionics

2025-11-07T06:35:39-08:00

D S Avionics Unlimited LLC owned a 1964 Piper PA-30 aircraft, which was insured under a policy issued by U.S. Specialty Insurance Company for the period between June 27, 2014, and June 27, 2015. In November 2014, DSA delivered the aircraft to a mechanic for maintenance at an Omaha airport. After a dispute between the mechanic and the airport owner, the mechanic was locked out of the hangar, and the aircraft was moved outside. When DSA attempted to retrieve the aircraft, a truck blocked its removal, and the airport owner refused to move it until storage fees were paid. The aircraft subsequently disappeared from view, and the airport owner informed authorities and the insurer that he was holding the aircraft pending payment. DSA reported the aircraft stolen and submitted a claim to USSIC, which was denied. USSIC filed suit in the District Court for Douglas County, Nebraska, seeking a declaration of noncoverage. DSA counterclaimed for breach of contract and bad faith. Both parties moved for summary judgment. The district court ruled in favor of USSIC, finding that DSA’s claim was not covered because there was no “accident” under the policy and that the Conversion Exclusion applied. The court also found that DSA failed to prove damages and that USSIC had an arguable basis for denial. DSA appealed, and the matter was moved to the Nebraska Supreme Court’s docket. The Nebraska Supreme Court held that DSA’s claim was within the policy’s coverage for “direct physical loss” caused by an “accident,” as defined by the policy. The court found that the airport owner’s actions constituted an “accident” from DSA’s perspective and that the Conversion Exclusion did not apply, as conceded by USSIC. The Supreme Court reversed the district court’s order and remanded for further proceedings regarding USSIC’s alleged bad faith and any damages due to DSA. View "U.S. Specialty Ins. Co. v. D S Avionics" on Justia Law

State v. Yeargin-Charles

2025-10-17T09:09:21-08:00

A law enforcement officer in Jackson County, Kansas, observed a vehicle with a license plate that was slanting to the right and visibly moving, described as "flapping in the wind." The officer initiated a traffic stop based on the belief that the license plate was not securely fastened as required by Kansas law. During the stop, the officer discovered drugs, drug paraphernalia, and an open container of alcohol in the purse of a passenger, who initially provided a false name. The passenger was subsequently charged with several offenses, including possession of methamphetamine and transportation of liquor in an open container. The passenger moved to suppress the evidence, arguing that the officer lacked reasonable suspicion to stop the vehicle because the license plate was otherwise legible and visible. The Jackson District Court denied the motion, relying on the officer’s testimony and persuasive federal authority interpreting the relevant Kansas statute. The case proceeded to trial, where a jury convicted the passenger on all counts. The Kansas Court of Appeals affirmed the district court’s denial of the suppression motion. The Supreme Court of the State of Kansas reviewed the case. It held that under K.S.A. 8-133(c), a license plate must be securely fastened to the vehicle, in addition to being visible and legible. The court found that the officer’s observation of the plate hanging askew and moving provided reasonable suspicion of a statutory violation, justifying the traffic stop. The court affirmed the decisions of both the Court of Appeals and the district court, holding that the stop was lawful and the evidence was properly admitted. View "State v. Yeargin-Charles " on Justia Law

Casarez v. Irigoyen Farms

2025-09-30T15:01:52-08:00

A fatal traffic accident occurred when a tractor trailer, driven by Andre Hill, ran a stop sign and collided with a vehicle driven by Olivia Mendoza, resulting in her death. Prior to the accident, Hill had picked up produce from Irigoyen Farms for delivery to a Walmart distribution center. The transportation of the produce involved several intermediaries: Irigoyen Farms contracted with a freight broker, who in turn contracted with other logistics companies, ultimately resulting in Hill being hired as an independent contractor by the motor carrier. Law enforcement determined that Hill’s extreme fatigue contributed to the crash. The decedent’s mother, Christina Casarez, filed suit in the Superior Court of Fresno County against Irigoyen Farms and Walmart, alleging motor vehicle negligence, general negligence, and wrongful death. She claimed that both defendants were directly negligent in their roles: Walmart for imposing contractual requirements that allegedly incentivized unsafe conduct, and Irigoyen Farms for loading the truck and sending Hill on his way despite knowledge of his fatigue. Both defendants moved for summary judgment, arguing that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempted Casarez’s claims. The superior court agreed, granting summary judgment in favor of both defendants. On appeal, the California Court of Appeal, Fifth Appellate District, reviewed the superior court’s decision de novo. The appellate court held that the FAAAA expressly preempts state law negligence claims against parties whose actions relate to the price, route, or service of a motor carrier with respect to the transportation of property, regardless of whether the party is a motor carrier, broker, or shipper. The court further held that the FAAAA’s safety exception did not apply because the claims did not directly concern the safety of the motor vehicle itself. The appellate court affirmed the superior court’s judgments in favor of Irigoyen Farms and Walmart. View "Casarez v. Irigoyen Farms" on Justia Law

Yazam, Inc. d/b/a Empower v. D.C. Department of For-Hire Vehicles

2025-09-25T05:03:02-08:00

Yazam, Inc., operating as Empower, is a private vehicle-for-hire company that provides a digital app connecting drivers with passengers. Unlike other rideshare platforms, Empower sells monthly subscriptions to drivers, who then set their own fares and retain the full payment from riders. The District of Columbia Department of For-Hire Vehicles (DFHV) ordered Empower to cease operations in the District for failing to register as required by law. Empower requested an expedited hearing before the District of Columbia Office of Administrative Hearings (OAH), which upheld the cease-and-desist order. Previously, DFHV had issued a similar order in 2020, which OAH upheld, but the District of Columbia Court of Appeals reversed, finding insufficient proof of immediate and irreparable harm to the public from Empower’s nonregistration. After that decision, DFHV issued a compliance order requiring Empower to register and provide documentation. When Empower did not respond, DFHV issued another cease-and-desist order, citing specific registration statutes and regulations. OAH found that Empower’s failure to register, along with other statutory violations, posed a substantial risk of immediate and irreparable harm, particularly through the impoundment of vehicles belonging to Empower drivers who were unaware of the risks. The District of Columbia Court of Appeals reviewed the OAH decision, applying a standard that requires affirmance if OAH made findings of fact on each contested issue, those findings are supported by substantial evidence, and the conclusions flow rationally from the findings. The court held that OAH properly upheld the cease-and-desist order based on the immediate and irreparable harm caused by Empower’s nonregistration, specifically the risk of vehicle impoundments. The court also rejected Empower’s due process arguments regarding discovery, hearing scheduling, and the telephonic nature of the hearing, finding no abuse of discretion or reversible error. The order of OAH was affirmed. View "Yazam, Inc. d/b/a Empower v. D.C. Department of For-Hire Vehicles" on Justia Law

Modzelewski's Towing & Storage, Inc. v. Commissioner of Motor Vehicles

2025-09-24T04:06:29-08:00

Two licensed wrecker services in Connecticut were summoned by state police to remove a severely damaged tractor trailer from a highway accident. The wrecker services used specialized equipment, including a costly rotator truck, to recover and tow the vehicle, then transported it to their storage facility. They sent an itemized invoice to the vehicle owner’s insurer, which included charges for the use of special equipment and supervisory personnel. The insurer paid the invoice under protest and subsequently filed a complaint with the Commissioner of Motor Vehicles, arguing that the charges were excessive and not permitted under state regulations. A Department of Motor Vehicles hearing officer determined that the wrecker services had overcharged for their nonconsensual towing services by using their own rate schedule based on equipment rather than the hourly labor rate set by the commissioner. Most equipment-based charges were disallowed, and the wrecker services were ordered to pay restitution and a civil penalty. The Superior Court dismissed the wrecker services’ administrative appeal, finding the hearing officer’s conclusions supported by substantial evidence. The Appellate Court affirmed, holding that the regulations required fees for exceptional services to be based solely on the hourly labor rate, excluding equipment costs. The Connecticut Supreme Court reviewed the case and concluded that the relevant regulation, § 14-63-36c (c), was ambiguous and could reasonably be interpreted to allow wrecker services to charge additional fees for exceptional services, including costs associated with special equipment, provided those fees are itemized and posted in accordance with regulatory requirements. The Court held that prohibiting such charges would prevent wrecker services from recouping necessary costs and could undermine the availability of exceptional towing services. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for further proceedings consistent with its interpretation. View "Modzelewski's Towing & Storage, Inc. v. Commissioner of Motor Vehicles" on Justia Law

Indianapolis Public Transportation Corporation v. Bush

2025-09-15T10:35:00-08:00

A 63-year-old man with a history of sciatica and alcohol-use disorder attempted to board a city bus in Indianapolis. Earlier that day, he had been hospitalized for intoxication but was released while still mildly intoxicated. That evening, after waiting at a bus stop, he approached a bus as it was preparing to leave. As the bus pulled away, he lost his balance and fell into the road, where he was run over and later died from his injuries. At the time of the incident, his blood-alcohol content was approximately 0.261. His mother, acting as the personal representative of his estate, filed a wrongful death suit against the public transportation corporation, alleging negligence. The Marion Superior Court presided over a jury trial in which the transportation corporation argued that the decedent was contributorily negligent, which would bar recovery. The jury viewed video footage of the incident and heard testimony regarding the decedent’s physical condition and intoxication. After deliberation, the jury found in favor of the estate and awarded damages, later reduced by statutory limits. The transportation corporation moved for judgment on the evidence and, after the verdict, for a motion to correct error, both of which the trial court denied. On appeal, the Indiana Court of Appeals reversed, finding the decedent contributorily negligent as a matter of law. The Indiana Supreme Court granted transfer, vacated the Court of Appeals’ opinion, and reviewed the trial court’s denial of the motion to correct error de novo. The Court held that the evidence, including the video footage and testimony, did not establish as a matter of law that the decedent was contributorily negligent. Multiple reasonable inferences could be drawn from the evidence, so the jury’s verdict was not clearly erroneous or unsupported. The Supreme Court affirmed the trial court’s denial of the motion to correct error. View "Indianapolis Public Transportation Corporation v. Bush" on Justia Law

Badger Helicopters Inc. v. FAA

2025-09-04T07:30:23-08:00

Several commercial air tour operators challenged federal regulations that banned all commercial air tours over Mount Rushmore National Memorial and Badlands National Park. The dispute arose after the Federal Aviation Administration (FAA) and the National Park Service, in response to statutory requirements and litigation, issued air tour management plans (ATMPs) in 2023 that prohibited such tours, citing negative impacts on visitor experience, wildlife, and tribal cultural resources. The operators argued that the agencies’ actions were arbitrary and capricious, violated the National Environmental Policy Act (NEPA), and failed to consider reasonable alternatives or aviation safety. Previously, the agencies had attempted to negotiate voluntary agreements with the tour operators, as permitted by the Air Tour Management Act. However, after one operator declined to participate, the agencies shifted to developing ATMPs. This change was influenced by a writ of mandamus issued by the United States Court of Appeals for the District of Columbia Circuit in In re Public Employees for Environmental Responsibility, which compelled the agencies to bring certain parks into compliance with the Act. The agencies then considered several alternatives before ultimately banning all commercial air tours in the final plans. The United States Court of Appeals for the Eighth Circuit reviewed the petitions for review filed by the tour operators. The court held that the agencies’ decision to end voluntary agreement negotiations and proceed with ATMPs was not arbitrary or capricious. It further found that the agencies complied with NEPA’s procedural requirements, used reasonable data, considered an adequate range of alternatives, and sufficiently addressed aviation safety concerns. The court concluded that the agencies’ decisions were reasonable and reasonably explained, and therefore denied the petitions to vacate the air tour management plans. View "Badger Helicopters Inc. v. FAA" on Justia Law

Bear Crest Limited LLC v. State of idaho

2025-09-03T08:03:51-08:00

The case involves a dispute between the owners and operators of a tourist attraction, Bear World, and the Idaho Transportation Department (ITD) over the closure of an intersection on Highway 20 in Madison County, Idaho. Bear Crest Limited LLC owns parcels of land leased to Yellowstone Bear World Inc., and Michael Ferguson is associated with both entities. In 1973, the original landowners (the Gideons) conveyed land to ITD’s predecessor for highway expansion, reserving “Access to the County Road Connection.” In 2016, as part of a highway upgrade to controlled-access status, ITD closed the intersection nearest Bear World, requiring visitors to use a more circuitous route, increasing travel distance by about five miles. After the intersection closure, the plaintiffs sued ITD for breach of contract and inverse condemnation, arguing that the closure violated the reserved access right in the Gideon deed and constituted a taking of property without just compensation. Both parties moved for summary judgment. The District Court of the Seventh Judicial District, Madison County, granted summary judgment to ITD, finding that the deed did not guarantee access to Highway 20, only to a county road, and that the closure did not amount to a compensable taking since alternative access remained. On appeal, the Supreme Court of the State of Idaho reversed in part, vacated the district court’s judgment, and remanded. The Court held that Bear Crest Limited had standing and that the Gideon deed unambiguously reserved access to the specific Highway 20 connection, not merely to a county road. The Court found that ITD’s closure of the intersection breached the deed and substantially impaired Bear Crest’s access rights, constituting a taking under Idaho law. The Court directed entry of partial summary judgment for Bear Crest on both claims, reserving damages and other issues for further proceedings. View "Bear Crest Limited LLC v. State of idaho" on Justia Law

Colorado Motor v. Town of Vail

2025-08-29T08:33:08-08:00

In 2022, a Colorado town enacted an ordinance restricting most vehicles from entering its pedestrian malls, with certain exceptions, including one for high-volume commercial carriers making frequent deliveries. In 2023, the town amended the ordinance to remove this exception, leaving only a provision allowing a town-approved contractor to deliver goods in the pedestrian areas. The Colorado Motor Carriers Association, representing trucking companies, challenged the amended ordinance, arguing it was preempted by federal law, and sought a preliminary injunction to halt its enforcement. The United States District Court for the District of Colorado granted a preliminary injunction against the amended ordinance, finding the Association was likely to succeed on the merits and would suffer irreparable harm. However, the court declined to enjoin the original ordinance, reasoning that the Association had not demonstrated irreparable injury, particularly given its delay in bringing suit after the original ordinance had been in effect for over a year. Both parties appealed: the town challenged the injunction against the amended ordinance, while the Association cross-appealed the denial of relief against the original ordinance. The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decisions. It held that the amended ordinance likely fell within the federal statutory safety exceptions, as it regulated with respect to motor vehicles and was genuinely responsive to safety concerns, based on legislative intent and a logical nexus to pedestrian safety. The court found the district court had erred in concluding the Association was likely to succeed on the merits and thus abused its discretion in granting the preliminary injunction. Regarding the original ordinance, the Tenth Circuit affirmed the district court’s denial of a preliminary injunction, holding that the Association’s delay in seeking relief undercut its claim of irreparable harm. The court reversed the injunction against the amended ordinance and remanded with instructions to dissolve it, while affirming the denial of relief as to the original ordinance. View "Colorado Motor v. Town of Vail" on Justia Law

MFA Enterprises, Inc. v. OSHRC

2025-08-28T07:30:26-08:00

West Central Agri Services operates a grain handling facility in Missouri, where employees load grain into railcars by accessing the tops of the cars, which are about fifteen feet above the ground. Employees open and close lids on the railcars to facilitate grain transfer, and a Trackmobile moves the railcars into position. An OSHA inspector, investigating an unrelated explosion, discovered that employees frequently worked atop railcars without wearing fall protection personal protective equipment (PPE), despite the facility having a fall protection system in place on one track and safety training instructing use of such equipment. Supervisors were aware of the lack of PPE use, and employees were not disciplined for noncompliance. Following the investigation, the Secretary of Labor cited West Central for a willful and serious violation of 29 C.F.R. § 1910.132(d)(1)(i), which requires employers to ensure employees use appropriate PPE for identified hazards. After a three-day evidentiary hearing, an administrative law judge (ALJ) of the Occupational Safety and Health Review Commission upheld the citation and imposed a penalty of $122,878.80, finding that West Central recognized the fall hazard and failed to enforce PPE use. The Commission denied discretionary review of the ALJ’s decision. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the Federal Railroad Administration (FRA) has exercised statutory authority over the working conditions on top of railcars, specifically through its 1978 policy statement asserting jurisdiction over walking-working surfaces and employee protection around railcars. As a result, the FRA’s authority preempts OSHA’s jurisdiction under 29 U.S.C. § 653(b)(1). The court vacated the citation and reversed the ALJ’s order, concluding that OSHA cannot enforce its PPE regulation for employees working on top of railcars at this facility. View "MFA Enterprises, Inc. v. OSHRC" on Justia Law

Estate of Schroeder v. Port Authority Transit Corp.

2025-08-26T10:00:10-08:00

An electronics technician employed by a regional transit authority was killed while working at a maintenance yard. His estate, through its administrator, brought suit against the transit authority and its parent entity, seeking recovery under the Federal Employers Liability Act (FELA), which provides a federal cause of action for employees of “common carriers by railroad” injured or killed during their employment. The transit line in question, known as the Speed Line, operates a 14.5-mile route between Philadelphia, Pennsylvania, and Lindenwold, New Jersey, providing frequent, high-capacity passenger service within a single metropolitan area. The Speed Line uses a third-rail electric system incompatible with other regional railroads, does not carry freight, and is not integrated with other rail lines. The United States District Court for the District of New Jersey initially denied the defendants’ motion to dismiss for lack of subject-matter jurisdiction, allowing jurisdictional discovery. After discovery, the District Court granted the renewed motion to dismiss, holding that the Speed Line is an urban rapid transit system rather than a railroad, and therefore FELA does not apply. The estate appealed this decision. The United States Court of Appeals for the Third Circuit reviewed the District Court’s legal conclusions de novo and its factual findings for clear error. The Third Circuit affirmed the District Court’s judgment, holding that the Speed Line is not a “common carrier by railroad” within the meaning of FELA. The court reasoned that the Speed Line’s services—short-haul, high-frequency passenger transportation within a single urban area—and its lack of integration with other railroads or freight operations, place it outside the scope of FELA. The court concluded that, as a rapid transit system, the Speed Line is not subject to FELA, and thus the federal courts lack subject-matter jurisdiction over the estate’s FELA claim. View "Estate of Schroeder v. Port Authority Transit Corp." on Justia Law

City of Billings v. TSA

2025-08-22T06:33:00-08:00

In 2020, the Transportation Security Administration (TSA) proposed a rule to address insider threats in airports, specifically targeting the risk that aviation workers with unescorted access to secured areas could facilitate the introduction of weapons or dangerous items onto aircraft. Instead of following the usual public notice-and-comment procedures required by the Administrative Procedure Act (APA), TSA provided notice and an opportunity to comment only to airport operators. The finalized rule, known as the National Amendment, required major airports to physically screen aviation workers entering certain secured areas and to acquire explosives-detection equipment. Noncompliance could result in civil enforcement actions by TSA. After TSA finalized the National Amendment in April 2023, various municipalities operating airports and a trade organization, Airport Council International-North America (ACI-NA), submitted timely requests for reconsideration, arguing that TSA lacked statutory authority, that the APA required public notice and comment, and that the rule unlawfully compelled local officials to implement a federal scheme. TSA denied all reconsideration requests, maintaining that its own regulations permitted it to amend airport security programs by providing notice and comment only to affected operators. The petitioners then sought review of TSA’s denial in the United States Court of Appeals for the District of Columbia Circuit. The United States Court of Appeals for the District of Columbia Circuit held that the National Amendment is a legislative rule subject to the APA’s notice-and-comment requirements, which TSA failed to follow. The court vacated the National Amendment but withheld its mandate, allowing TSA time to promulgate a procedurally proper rule or inform the court if no rule is needed. The court required TSA to submit periodic status reports until a final resolution. View "City of Billings v. TSA" on Justia Law

Grand Trunk Corp. v. Transportation Security Administration

2025-08-21T13:00:32-08:00

Two affiliated freight railroad companies challenged a series of security directives issued by the Transportation Security Administration (TSA) that required certain high-risk and strategically significant railroads to implement extensive cybersecurity measures. These directives, which were updated annually, imposed significant compliance costs and were motivated by ongoing and evolving threats from foreign adversaries such as Russia and China. The railroads argued that the directives should have undergone notice-and-comment rulemaking and that the ongoing nature of the cybersecurity threat did not constitute an “emergency” justifying bypassing those procedures. The petitioners sought direct review in the United States Court of Appeals for the Seventh Circuit, as permitted by statute, after the TSA issued new versions of the directives in May 2024, July 2024, and May 2025. The court consolidated the challenges because the directives were substantively identical. The railroads argued that TSA was required to conduct notice-and-comment rulemaking, perform a cost-benefit analysis, and that TSA lacked statutory authority to issue the directives. They also contended that the directives were arbitrary and capricious. The United States Court of Appeals for the Seventh Circuit denied the petitions. The court held that the ongoing cybersecurity threats described in the directives constituted an emergency within the meaning of 49 U.S.C. § 114(l)(2), allowing TSA to bypass notice-and-comment procedures. The court further held that TSA was not required to conduct a cost-benefit analysis for security directives, as the relevant statutory provision applied only to regulations, not directives. The court also found that TSA had sufficient statutory authority to issue the directives and that the directives were not arbitrary or capricious. The petitions for review were therefore denied. View "Grand Trunk Corp. v. Transportation Security Administration" on Justia Law

Long v. Bondi

2025-08-14T10:00:39-08:00

A United States citizen, formerly known as Paul Anderson and now Saadiq Long, was placed on the federal government’s Terrorist Screening Dataset (commonly called the Terrorist Watchlist) and, at one point, on its No Fly List subset. After experiencing travel restrictions, employment issues, and other alleged harms, Long challenged his placement on these lists, asserting constitutional and statutory violations. He claimed that his inclusion was based on impermissible factors such as race, religion, and protected activities, and that the government’s information-sharing practices and redress procedures were unlawful. While the litigation was ongoing, Long was removed from the No Fly List, but remained on the broader Watchlist. He also alleged that his Watchlist status led to the denial of credentials necessary for his work as a truck driver. The United States District Court for the Eastern District of Virginia initially transferred some of Long’s claims to the Fourth Circuit and stayed others. After Long’s removal from the No Fly List, a prior Fourth Circuit panel found his No Fly List claims moot and remanded for the district court to determine which claims remained justiciable. On remand, the district court dismissed all of Long’s claims for lack of subject matter jurisdiction, finding that his removal from the No Fly List mooted those claims and that he lacked standing for his Watchlist-related claims, as his alleged injuries were either resolved or not sufficiently imminent. The United States Court of Appeals for the Fourth Circuit vacated the district court’s dismissal. The Fourth Circuit held that, in light of the Supreme Court’s decision in FBI v. Fikre, Long’s removal from the No Fly List did not necessarily moot his claims, as the government had not shown it could not repeat the challenged conduct. The court also found that Long had standing to challenge his Watchlist status based on the denial of transportation credentials, and remanded for the district court to consider the merits of his claims. View "Long v. Bondi" on Justia Law

WILLIAMS V. J.B. HUNT TRANSPORT, INC.

2025-08-12T08:30:46-08:00

Three California-based truck drivers who worked for a national transportation company challenged the legality of their employer’s compensation system. The drivers alleged that the company’s pay plan, which combined hourly wages with a bonus based on certain activities, violated California’s Labor Code by failing to properly compensate for nonproductive time and by not reimbursing necessary business expenses, such as personal cell phone use. They also claimed the company failed to provide accurate wage statements and sought penalties under the Private Attorneys General Act (PAGA) and California’s Unfair Competition Law. After the case was removed from state court, the United States District Court for the Central District of California denied class certification and granted summary judgment to the employer on most claims. The court found that the pay plan qualified for a statutory “safe harbor” because it paid at least minimum wage for all hours worked, with additional bonuses for certain activities, and thus did not require separate compensation for nonproductive time. The court also found no evidence that the employer knew or should have known about any off-the-clock work. The only claims that proceeded to trial were for failure to reimburse business expenses. At trial, the jury found in favor of the employer, and the court entered judgment accordingly, also awarding costs to the employer. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the employer’s pay plan met the requirements of California Labor Code § 226.2(a)(7)’s safe harbor, as it paid at least minimum wage for all hours worked and provided additional bonuses. The court also found no genuine dispute of material fact regarding off-the-clock work or wage statement violations, and it upheld the district court’s evidentiary rulings, jury instructions, and award of costs. View "WILLIAMS V. J.B. HUNT TRANSPORT, INC." on Justia Law

DCC Propane LLC v. KMT Enterprises, Inc.

2025-08-05T06:30:08-08:00

A company that supplies oil and propane hired a trucking business to deliver 10,000 gallons of heating oil to its property in Putnam, Connecticut. During the delivery, the trucking company’s employee allegedly failed to monitor the filling process, resulting in an overflow that contaminated the soil and groundwater. The supplier claimed it incurred over $500,000 in remediation and related expenses due to the spill. The supplier filed a lawsuit in the United States District Court for the District of Connecticut, asserting common-law negligence and recklessness claims under Connecticut law. The complaint cited specific federal Hazardous Materials Regulations (HMRs) as evidence of the trucking company’s duties and alleged breaches. The trucking company moved to dismiss, arguing that the supplier’s claims were preempted by the federal Hazardous Materials Transportation Act (HMTA) and, alternatively, that the recklessness claim was insufficiently pleaded. The district court granted the motion, holding that the HMTA preempted the state-law claims and that the recklessness claim failed to state a claim. On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The Second Circuit held that the HMTA does not preempt the supplier’s Connecticut common-law claims for negligence and recklessness, so long as those claims are based on duties that are “substantively the same” as federal requirements under the HMTA and HMRs. The court found that the mental state required for negligence and recklessness under Connecticut law is not inconsistent with the HMTA’s standards for civil violations. Accordingly, the Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "DCC Propane LLC v. KMT Enterprises, Inc." on Justia Law

Regueiro v. American Airlines, Inc.

2025-07-30T11:04:25-08:00

The case involves José Ramón López Regueiro, who filed a lawsuit against American Airlines, Inc. under Title III of the Helms-Burton Act. Regueiro alleged that his father purchased Cuba’s main airport, which was later confiscated by Fidel Castro’s regime. Regueiro inherited his father’s interest in the airport and became a U.S. citizen in 2015. He claimed that American Airlines trafficked in the confiscated property by operating flights in and out of the airport. The United States District Court for the Southern District of Florida dismissed the case. The court agreed with American Airlines that the Helms-Burton Act implicitly required the property owner to be a U.S. citizen when the property was confiscated and the plaintiff to be a U.S. citizen when they acquired an interest in the property. Since Regueiro’s father was not a U.S. citizen when the airport was confiscated and Regueiro became a U.S. citizen only after inheriting the property, the court ruled that Regueiro failed to state a claim. The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s interpretation. The appellate court concluded that the Helms-Burton Act does not impose the preconditions that American Airlines argued. The Act provides a cause of action to any U.S. national who owns a claim to confiscated property, regardless of the owner’s citizenship status at the time of confiscation or acquisition. The court also rejected American Airlines’s argument that Regueiro’s ownership of shares in the company that owned the airport did not constitute an ownership interest in the airport itself. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Regueiro v. American Airlines, Inc." on Justia Law

Muir v. Department of Homeland Security

2025-07-25T07:01:59-08:00

Michael Muir, who has a congenital birth defect presenting as a hernia in his right scrotum, challenged the Transportation Security Administration’s (TSA) Final Rule authorizing the use of Advanced Imaging Technology (AIT) scanners at airport security checkpoints. Muir argued that the scanners, which use electromagnetic radiation, flag his hernia as a threat, leading to painful and potentially life-threatening pat-downs. He claimed that the Final Rule and TSA’s standard operating procedures (SOPs) are arbitrary and capricious, contrary to TSA’s statutory authority, and violate Section 504 of the Rehabilitation Act of 1973. The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court found that Muir had not raised his statutory challenges during the rulemaking process, resulting in forfeiture of those claims. However, the court agreed with Muir’s Rehabilitation Act claim, noting that TSA’s failure to provide an accommodation for his disability could be a violation of the Act. The court determined that Muir had identified a reasonable accommodation—screening with a walk-through metal detector (WTMD)—and remanded the case to TSA to determine if this accommodation would impose an undue burden on the agency. The court denied Muir’s other challenges to the Final Rule and his motion to supplement the record. The court emphasized that TSA must conduct the appropriate administrative process to address the implementation of Muir’s reasonable accommodation and explore alternative accommodations if necessary. View "Muir v. Department of Homeland Security" on Justia Law

United States v. Adamu

2025-07-21T06:30:11-08:00

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine. The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt. The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law

Crowley Government Services, Inc. v. General Services Administration

2025-07-18T07:01:16-08:00

Crowley Government Services, Inc. ("Crowley") entered into a contract with the Department of Defense United States Transportation Command ("USTRANSCOM") in 2016 to provide transportation coordination services, which involved hiring motor carriers to transport freight. The General Services Administration ("GSA"), not a party to the contract, began auditing Crowley's bills under a provision of the Transportation Act of 1940, claiming Crowley overbilled USTRANSCOM by millions of dollars. GSA sought to recover these overcharges by garnishing future payments to Crowley. The United States District Court for the District of Columbia dismissed Crowley's Administrative Procedure Act ("APA") claims, holding that the claims were essentially contractual and fell within the exclusive jurisdiction of the Court of Federal Claims. The D.C. Circuit reversed, finding that Crowley's suit was not a contract claim and remanded the case. On remand, the District Court held that GSA could audit both carriers and non-carriers but agreed with Crowley that the USTRANSCOM Contracting Officer's interpretations governed any GSA audits. The court enjoined GSA from issuing Notices of Overcharge ("NOCs") contrary to the Contracting Officer's determinations. The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that 31 U.S.C. § 3726(b) allows GSA to audit only bills presented by carriers and freight forwarders. The court found that Crowley is not a carrier because it does not physically transport freight nor is it contractually bound to help perform the movement of goods. Consequently, the court reversed the District Court's decision on the scope of § 3726(b) and remanded for further proceedings, permanently enjoining GSA from conducting postpayment audits of Crowley's bills. View "Crowley Government Services, Inc. v. General Services Administration" on Justia Law

Axalta Coating Systems LLC v. Federal Aviation Administration

2025-07-15T09:00:14-08:00

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy. The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review. The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Cox v. Total Quality Logistics, Inc.

2025-07-08T11:00:14-08:00

Robert Cox, acting as the personal representative and special administrator of the estate of Greta Cox, sued Total Quality Logistics, Inc. and Total Quality Logistics, LLC (collectively, TQL) for negligence under Ohio law. Cox alleged that TQL, in its role as a freight broker, negligently hired an unsafe motor carrier, Golden Transit, Inc., which resulted in a motor vehicle crash that killed his wife, Greta Cox. The crash occurred when the driver of the motor carrier, Amarjit Singh Khaira, failed to slow down in a construction zone and collided with Greta Cox's vehicle. The United States District Court for the Southern District of Ohio dismissed the case, ruling that Cox’s claims were preempted by the Federal Aviation Administration Authorization Act (FAAAA), specifically 49 U.S.C. § 14501(c). The district court found that the FAAAA preempted the state law claims because they related to the services of a broker with respect to the transportation of property and did not fall within the Act’s safety exception. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred in its interpretation of the FAAAA’s safety exception. The Sixth Circuit concluded that the safety exception, which preserves the safety regulatory authority of a state with respect to motor vehicles, includes common law claims like Cox’s negligent hiring claim. The court reasoned that such claims are genuinely responsive to safety concerns and directly involve motor vehicles and motor vehicle safety. Therefore, the court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cox v. Total Quality Logistics, Inc." on Justia Law

Grand Trunk Corporation v STB

2025-07-08T10:00:17-08:00

Several rail carriers challenged a Final Rule issued by the Surface Transportation Board (STB) that allows a railway shipper or receiver to request a "reciprocal switching agreement." This agreement requires a rail carrier with a monopoly over a certain rail line to compete with another carrier for specific rail traffic. The carriers argued that the Final Rule exceeded the STB's statutory authority under the Staggers Rail Act of 1980, which grants the agency authority to prescribe reciprocal switching. They also contended that aspects of the Final Rule exceeded the Board's ancillary powers and were arbitrary, capricious, and unsupported by the record. The STB issued the Final Rule after a notice-and-comment period, aiming to address service performance issues of Class I rail carriers, which were exacerbated by the COVID-19 pandemic. The Board held a hearing in April 2022 and required several Class I carriers to submit service recovery plans. Subsequently, the Board proposed new regulations to improve service by increasing competition, leading to the Final Rule. The rule establishes procedures for shippers or receivers to request reciprocal switching agreements if the incumbent carrier fails to meet certain performance standards. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the Final Rule exceeded the STB's statutory authority because it did not require a finding of inadequate service by the incumbent carrier before prescribing a reciprocal switching agreement. The court emphasized that the Staggers Rail Act requires such a finding to determine that a reciprocal switching agreement is "in the public interest." Consequently, the court granted the petition, vacated the Final Rule, and remanded the case to the STB for further proceedings. View "Grand Trunk Corporation v STB" on Justia Law

Whatley v. Canadian Pacific Railway Co.

2025-07-03T07:30:22-08:00

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo. The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment. The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

Better Way Ford, LLC v. Ford Motor Company

2025-07-01T13:30:34-08:00

In 2016, Tucker Cianchette secured a multimillion-dollar judgment in Maine Superior Court against his father, step-mother, and two LLCs after they backed out of a 2015 agreement that would have given him sole control of a Ford dealership. Following this, in 2021, Eric and Peggy Cianchette, along with Cianchette Family, LLC, and Better Way Ford, LLC, filed a lawsuit alleging that Ford Motor Company violated state and federal laws during the failed 2015 negotiations and through false testimony by Ford employees in Tucker's 2016 suit. The 2021 lawsuit was initially filed in Maine Superior Court but was removed to the United States District Court for the District of Maine. The District Court dismissed all claims against Ford, leading the plaintiffs to appeal. The plaintiffs argued that Ford's actions during the 2015 negotiations and the 2016 lawsuit constituted violations of Maine's civil perjury statute, the Dealers Act, the federal Automobile Dealers' Day in Court Act, and also amounted to breach of contract and tortious interference with contract. The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The Court of Appeals held that the plaintiffs failed to plausibly allege that Ford made any false representations or that any reliance on such representations was justified. The court also found that the plaintiffs' claims under the Dealers Act were barred by res judicata due to a prior ruling by the Maine Motor Vehicle Franchise Board. Additionally, the court concluded that the implied covenant of good faith and fair dealing did not apply to the breach of contract claims under Michigan law, as the SSA explicitly granted Ford the right to approve changes in ownership. View "Better Way Ford, LLC v. Ford Motor Company" on Justia Law

Solondz v. FAA

2025-06-27T07:02:02-08:00

Michael Solondz, a commercial airline pilot, was diagnosed with anxiety and prescribed mirtazapine after experiencing side effects from another medication. Mirtazapine effectively managed his anxiety without significant side effects. Solondz sought medical clearance from the Federal Aviation Administration (FAA) to resume flying, but the FAA categorically disallows pilots from flying while taking mirtazapine, despite allowing conditional approvals for other antidepressants. The FAA denied Solondz's request for a Special Issuance medical certificate multiple times, citing his use of mirtazapine, anxiety, sleep apnea, optic neuritis, and a history of atrial fibrillation. Solondz provided evidence that his conditions were well-managed and that mirtazapine did not cause significant side effects. The FAA's final denial letter reiterated these reasons and added a concern about a potential malignant melanoma diagnosis, which Solondz disputed. The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the FAA failed to provide a reasonable explanation for categorically disallowing pilots taking mirtazapine from obtaining medical certification. The court noted that the FAA's process for conditionally approving other antidepressants involves a six-month waiting period and individualized medical assessments, which could also apply to mirtazapine. The court vacated the FAA's final denial letter and remanded the case for further explanation. The court emphasized that the FAA must articulate a clear rationale for its policy and avoid offering explanations that contradict the evidence. The petition for review was granted, and the case was remanded to the FAA for further proceedings consistent with the court's opinion. View "Solondz v. FAA" on Justia Law

Commonwealth v. Linton

2025-06-17T05:14:49-08:00

In this case, the appellant, Brendan Linton, was riding his bicycle on a heavily trafficked state highway in Butler Township, Pennsylvania. The highway had one lane of travel in each direction, with a speed limit varying from 45 to 55 mph. Pennsylvania State Trooper Joshua Osche observed Linton riding his bicycle at speeds significantly lower than the posted speed limits, causing a buildup of traffic behind him. Despite multiple vehicles successfully passing Linton, Trooper Osche eventually initiated a traffic stop, citing Linton for impeding the normal and reasonable movement of traffic under Section 3364(b)(2) of the Vehicle Code. The Court of Common Pleas of Butler County found Linton guilty of violating Section 3364(b)(2), concluding that he should have moved to the berm area to allow faster-moving traffic to pass. The court imposed a $25 fine. The Superior Court of Pennsylvania affirmed the judgment, agreeing that Linton's failure to use the berm constituted a violation of the statute. The Supreme Court of Pennsylvania reviewed the case to determine whether Section 3364(b)(2) requires pedalcyclists to leave the roadway whenever faster-moving traffic approaches. The Court concluded that the statute calls for a fact-bound assessment of reasonableness, taking all relevant considerations into account. The Court held that there may be circumstances under which a factfinder could determine that the "reasonable efforts" a pedalcycle operator must exert include temporarily leaving the roadway. However, the Court rejected the rigid interpretations of both the appellant and the lower courts, emphasizing that the statute does not mandate pedalcyclists to always vacate the roadway for faster-moving traffic. The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to reconsider the sufficiency of the evidence using the proper legal standard. View "Commonwealth v. Linton" on Justia Law

P. v. Porter

2025-06-04T06:00:46-08:00

Nathaniel Gabriel Porter was cited for a traffic infraction under California Vehicle Code section 23123.5(a) for holding and viewing a mapping application on his wireless phone while driving. Section 23123.5(a) prohibits drivers from holding and operating a handheld wireless telephone unless it is used in a voice-operated and hands-free manner. Porter contested the citation, arguing that viewing a mapping application did not constitute "operating" the phone as defined by the statute. The traffic commissioner found Porter guilty and imposed a $158 fine. Porter appealed to the appellate division of the Santa Clara County Superior Court, which reversed his conviction. The appellate division concluded that "operating" a wireless telephone required active use or manipulation, such as talking, listening, emailing, or browsing the internet, and that merely observing GPS directions did not meet this threshold. The court suggested that the Legislature might need to amend the statute to address evolving technology and distracted driving concerns. The California Court of Appeal, Sixth Appellate District, reviewed the case to ensure uniformity in legal interpretation. The court examined the statutory language, legislative history, and public policy considerations. It concluded that "operating" under section 23123.5(a) includes all uses of a handheld phone's functions while driving, including viewing a mapping application. The court determined that the Legislature intended to prohibit all handheld phone use while driving to mitigate distracted driving risks. Consequently, the appellate division's judgment was reversed, and Porter's traffic conviction was reinstated. View "P. v. Porter" on Justia Law

Seven County Infrastructure Coalition v. Eagle County

2025-06-02T08:35:07-08:00

A group of seven Utah counties, known as the Seven County Infrastructure Coalition, applied to the U.S. Surface Transportation Board for approval to construct an 88-mile railroad line in Utah's Uinta Basin. This project aimed to connect the oil-rich region to the national freight rail network, facilitating crude oil transportation to Gulf Coast refineries. The Board prepared a 3,600-page Environmental Impact Statement (EIS) addressing the project's significant environmental effects and feasible alternatives. However, the EIS did not fully analyze the potential environmental impacts of increased upstream oil drilling and downstream oil refining. The U.S. Court of Appeals for the D.C. Circuit reviewed the case after petitions were filed by a Colorado county and several environmental organizations. The D.C. Circuit found numerous violations of the National Environmental Policy Act (NEPA) in the EIS, specifically criticizing the Board for not sufficiently analyzing the environmental effects of upstream oil drilling and downstream oil refining. Consequently, the D.C. Circuit vacated both the EIS and the Board's final approval order for the railroad line. The Supreme Court of the United States reviewed the case and reversed the D.C. Circuit's decision. The Court held that the D.C. Circuit failed to afford the Board the substantial judicial deference required in NEPA cases. The Supreme Court clarified that NEPA requires agencies to focus on the environmental effects of the proposed project itself, not on separate projects that are distinct in time or place. The Court concluded that the Board's EIS complied with NEPA's procedural requirements by addressing the environmental effects of the 88-mile railroad line, without needing to evaluate the impacts of upstream oil drilling or downstream oil refining. The case was remanded for further proceedings consistent with this opinion. View "Seven County Infrastructure Coalition v. Eagle County" on Justia Law

In re State Airport Hangar Lease Disputes

2025-05-02T06:42:48-08:00

In 2019, the Vermont Agency of Transportation (AOT) increased the rental fees for hangar space at state-owned airports. Five tenants, who own hangar facilities at the Northeast Kingdom International Airport and the Stowe-Morrisville State Airport, appealed the rate increases to the Transportation Board. They argued that the rent increase did not comply with the terms of their leases and was arbitrary. The leases allowed AOT to adjust rent based on the Consumer Price Index for All Urban Consumers (CPI-U), current market value for the land, and maintenance costs for the airport. The tenants contended that AOT improperly considered changes outside the previous lease term. The Transportation Board consolidated the tenants' appeals and reviewed the administrative records and memoranda submitted by both parties. The Board found that AOT had invested significantly in airport improvements and conducted a market-value analysis for leased space. However, the Board noted that details of the analysis were not included in the administrative record. The Board concluded that AOT was permitted to consider changes to market value and maintenance costs outside of the prior lease term but admonished AOT to provide a clearer analysis in the future. The tenants appealed to the Vermont Supreme Court, arguing that the rent increases were arbitrary and capricious due to a lack of transparent methodology. The Supreme Court affirmed the Board's conclusion that AOT could consider changes outside the prior lease term but reversed and remanded the decision concerning the fairness of the rent increases. The Court held that the Board should have sought a complete record from AOT to determine whether the rent levels were fair and conducted a new adjudication consistent with this opinion. View "In re State Airport Hangar Lease Disputes" on Justia Law

Zenith Insurance Co. v. Workers' Comp. Appeals Bd.

2025-05-01T12:00:58-08:00

Javier Hernandez, a farm laborer employed by Ceja Reyes, Inc., was injured in a vanpool accident while commuting home from work. Hernandez did not have a driver's license or own a car, and he used a vanpool arranged by another employee, paying $10 per day for the service. The vanpool was not provided by Ceja Reyes, and the driver at the time of the accident did not have a valid California driver's license. Hernandez sustained catastrophic injuries, including a right leg amputation, and filed a workers' compensation claim. A workers' compensation judge initially heard the case and concluded that Hernandez's claim was not barred by the going and coming rule, applying the special risk and dual purpose exceptions. Zenith Insurance Company, Ceja Reyes's workers' compensation insurer, denied the claim and filed a petition for reconsideration. The Workers' Compensation Appeals Board (the Board) denied the petition and adopted the judge's report, leading Zenith to file a petition for writ of review with the California Court of Appeal, Third Appellate District. The California Court of Appeal reviewed the case and determined that the Board's application of the special risk and dual purpose exceptions was erroneous. The court found that the special risk exception did not apply because the injury did not occur just outside the employer's premises and there was no relationship between the risk and the location of the premises or conditions over which the employer had control. Additionally, the dual purpose exception was deemed inapplicable as the commute did not provide an incidental benefit to the employer beyond the normal need for the employee's presence at work. Consequently, the court annulled the Board's order and remanded the case for further proceedings consistent with its opinion. View "Zenith Insurance Co. v. Workers' Comp. Appeals Bd." on Justia Law

Lunn v. Continental Motors, Inc.

2025-04-29T12:12:12-08:00

William D. Lunn, individually and as the representative of the estates of his three deceased children, filed a wrongful death lawsuit against Continental Motors, Inc. (CMI) in October 2009, alleging a design defect caused an airplane crash that killed his children. In September 2012, CMI made an unapportioned offer of judgment for $300,000, which Lunn rejected. After a lengthy litigation process, a jury found in favor of CMI. Lunn moved for a new trial, which the district court granted in February 2021. CMI appealed, arguing the claims were barred by the statute of repose under the General Aviation Revitalization Act. The Court of Civil Appeals (COCA) reversed the district court's decision. CMI then sought attorney's fees, claiming entitlement under the offer of judgment statute since the judgment was less than their offer. The district court denied the motion, ruling the unapportioned offer invalid. CMI appealed this decision. COCA affirmed the district court's ruling, referencing prior cases that required offers of judgment to be apportioned among plaintiffs to be valid. The Supreme Court of the State of Oklahoma reviewed the case to address whether an offer of judgment under 12 O.S.2021, § 1101.1(A) must be apportioned among multiple plaintiffs. The court held that such offers must indeed be apportioned to allow each plaintiff to independently evaluate the settlement offer. The court emphasized that unapportioned offers create confusion and hinder the plaintiffs' ability to assess the offer's value relative to their claims. Consequently, the court vacated COCA's opinion and affirmed the district court's judgment, ruling CMI's unapportioned offer invalid. View "Lunn v. Continental Motors, Inc." on Justia Law

Adler v. Gruma Corporation

2025-04-16T09:00:09-08:00

Plaintiffs Charles and Grant Adler, through their business entity CM Adler LLC, distributed tortillas and other food products of Defendant Gruma Corporation to grocery stores in central New Jersey under a "Store Door Distributor Agreement" (SDDA). When Defendant terminated the relationship, Plaintiffs filed a lawsuit alleging retaliatory termination due to their organizing efforts with other distributors. Plaintiffs claimed violations of state and federal labor laws, including failure to pay minimum wages and unlawful deductions, and argued that the SDDA was a franchise agreement subject to New Jersey's Franchise Practices Act, which forbids termination without cause. The United States District Court for the District of New Jersey dismissed the case, concluding that Texas law governed under the SDDA and the case should proceed to arbitration. The District Court did not address the applicability of the Federal Arbitration Act (FAA) or Plaintiffs' exemption argument under 9 U.S.C. § 1. It found the parties had contracted for Texas law, under which the arbitration agreement was enforceable, and rejected Plaintiffs' bid to apply New Jersey law instead. The District Court also decided that Charles and Grant Adler, who did not sign the contract, were estopped from challenging its arbitration provision because they acted as parties to the contract when they performed the LLC’s work. The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the FAA does not apply to the SDDA because Plaintiffs are transportation workers engaged in interstate commerce. The Court of Appeals found that the District Court erred in its choice-of-law analysis by failing to consider the impact of New Jersey public policies on its arbitrability ruling. The Court of Appeals vacated the order compelling arbitration and remanded for the District Court to complete the choice-of-law analysis under the correct framework and to reevaluate whether the individual Plaintiffs, who did not sign the arbitration agreement, are bound by its terms. View "Adler v. Gruma Corporation" on Justia Law

N'Da v. Golden

2025-04-04T05:35:02-08:00

A business owner and his company, which provides non-emergency medical transportation, challenged the constitutionality of a Nebraska statute requiring a showing of "public convenience and necessity" to obtain a certificate to operate such services. They argued that the statute violated the Nebraska Constitution's due process, special legislation, and special privileges and immunities clauses. They claimed the requirement protected existing providers from competition and harmed the public by reducing service quality. The district court for Lancaster County rejected their constitutional challenges and dismissed their complaint. The court applied a rational basis test to the due process claim, finding the statute rationally related to a legitimate state interest in preventing destructive competition and ensuring reliable transportation services. The court also found the statute did not create an arbitrary or unreasonable classification or a closed class, thus rejecting the special legislation claim. Finally, the court determined the statute did not grant irrevocable special privileges or immunities, dismissing the special privileges and immunities claim. On appeal, the Nebraska Supreme Court affirmed the district court's rejection of the facial constitutional challenges, agreeing that the statute was rationally related to a legitimate state interest and did not violate the special legislation or special privileges and immunities clauses. However, the Supreme Court vacated the district court's order to the extent it ruled on as-applied challenges, determining that such challenges should be raised in an application for certification and an appeal from any denial by the Public Service Commission. View "N'Da v. Golden" on Justia Law

State of Maine v. Ray

2025-03-20T07:05:04-08:00

Christopher Ray was observed by a Cumberland Police Department officer riding his bicycle slightly to the left of the white fog line on Tuttle Road. The officer, traveling behind Ray and another cyclist, instructed them to ride single file. Ray responded with an expletive, prompting the officer to stop them and issue Ray a violation summons for failing to keep to the right of the road, as required by 29-A M.R.S. § 2063(2). Ray contested the violation, and a bench trial was held in the District Court (Portland). The court found Ray had committed the traffic infraction of not operating his bicycle on the right portion of the way as far as practicable and imposed a fine of $151. Ray appealed the decision to the Maine Supreme Judicial Court. The Maine Supreme Judicial Court reviewed the case de novo, focusing on the interpretation of 29-A M.R.S. § 2063(2). The Court found the statute ambiguous regarding where cyclists must operate when the command to ride to the right applies. The Court noted that the terms "roadway" and "way" were not clearly defined, and the statute's language left it up to the cyclist to determine what was safe, making enforcement difficult. The Court concluded that the ambiguity must be resolved in favor of Ray, vacated the adjudication, and remanded the case for entry of judgment in favor of Ray. View "State of Maine v. Ray" on Justia Law

Hoffstead v Northeast Illinois Regional Commuter Railroad Corp

2025-03-20T06:00:38-08:00

Timothy Hoffstead, a canine handler for Metra, was suspended after testing positive for amphetamines and opioids during a random drug test. Hoffstead attributed the positive result to his prescribed medications for ADD, migraines, and a wrist injury. The medical review officer (MRO) attempted to contact Hoffstead for an explanation but was unsuccessful. Consequently, Hoffstead was suspended and later not considered for an open canine handler position. Despite providing proof of his prescriptions and having his test results revised to negative, Metra required him to complete a rehabilitation program. Hoffstead eventually returned to work but left Metra for other employment. The United States District Court for the Northern District of Illinois granted summary judgment in favor of Metra. The court found that Hoffstead failed to demonstrate that Metra's actions were due to his disability. The court also ruled that it could not consider Hoffstead's claim regarding the exercise of seniority under the collective bargaining agreement (CBA) due to the Railway Labor Act (RLA), which prohibits courts from interpreting CBAs. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Hoffstead did not provide sufficient evidence to show that Metra's actions were motivated by his disability. The court noted that Hoffstead's failure to respond to the MRO and his decision to waive an investigation in favor of the rehabilitation program were the primary reasons for Metra's actions. The court also found that the RLA did not preclude adjudicating Hoffstead's claim regarding the seniority rules but concluded that Hoffstead failed to demonstrate a link between his disability and Metra's actions. View "Hoffstead v Northeast Illinois Regional Commuter Railroad Corp" on Justia Law

LA ANYANE v. THE STATE

2025-03-04T05:32:34-08:00

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content. The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors. The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed. Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

D.J. v. First Student, Inc.

2025-02-28T13:30:07-08:00

In 2019, fourth-grader D.J. was attending KIPP Victory Academy, which had contracted with First Student, Inc. to transport students. On October 23, 2019, substitute bus driver Tomika Richardson dropped D.J. off at the wrong corner of an intersection. The next day, Richardson again dropped D.J. off at the same incorrect location. As D.J. crossed the street, a vehicle maneuvered around the bus and struck him, causing injuries. The hit-and-run driver was never identified. D.J., through his mother, sued First Student and Richardson, alleging negligence. The case went to trial in the Circuit Court of St. Louis. The jury found in favor of Richardson on one count but ruled in favor of D.J. on another count, awarding $1.3 million in damages. The circuit court overruled First Student's motions for judgment notwithstanding the verdict (JNOV) and a new trial, leading to First Student's appeal. The Supreme Court of Missouri reviewed the case. The court held that the criminal act of the hit-and-run driver was an intervening and superseding cause, breaking the causal chain and relieving First Student of liability. The court determined that D.J. failed to prove that First Student's actions were the proximate cause of his injuries. Consequently, the Supreme Court of Missouri vacated the circuit court's judgment and remanded the case with instructions to enter judgment in favor of First Student. View "D.J. v. First Student, Inc." on Justia Law

Conservation Law Foundation, Inc. v. Academy Express, LLC

2025-02-20T17:00:07-08:00

An environmental group, Conservation Law Foundation (CLF), sued Academy Express, LLC (Academy), a transportation company, alleging that Academy violated the Clean Air Act (CAA) by idling its buses beyond state limits in Massachusetts and Connecticut. CLF claimed that its members were harmed by breathing polluted air from Academy's buses. Academy moved for summary judgment, arguing that CLF lacked associational standing. The district court agreed and granted Academy's motion, holding that CLF could not demonstrate that its members suffered a concrete injury traceable to Academy's conduct. The United States District Court for the District of Massachusetts found that only two of CLF's members, Wagner and Morelli, had alleged injuries-in-fact, but their injuries were not traceable to Academy's idling due to the presence of other potential pollution sources in the urban environment. The court did not address the standing of additional members disclosed by CLF after the close of fact discovery or the expert testimony submitted by CLF. The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's narrow interpretation of injury-in-fact. The appellate court held that breathing polluted air and reasonable fear of health effects from pollution are cognizable injuries. It also found that recreational harms do not require a change in behavior to be considered injuries-in-fact. The court emphasized that traceability does not require a conclusive link but can be established through geographic proximity and expert testimony. The First Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. The district court was instructed to determine the scope of the record, make necessary factual findings, and apply the correct legal standards for injury-in-fact and traceability. The appellate court did not address redressability, leaving it for the district court to consider if necessary. View "Conservation Law Foundation, Inc. v. Academy Express, LLC" on Justia Law

Schultz vs. Great Plains Trucking, Inc.

2025-02-11T13:30:04-08:00

Great Plains Trucking Inc. and Lennis H. Beck (defendants) appealed a circuit court judgment in favor of Carrie S. Schultz and Robert C. Schultz, Sr. (plaintiffs), surviving parents of Robert C. Schultz, Jr., in a wrongful death action. Beck, a truck driver for Great Plains, collided with the plaintiffs' vehicle, resulting in the death of their son. The collision occurred in Wentzville, Missouri, under dark and rainy conditions. The plaintiffs' vehicle had fishtailed and was struck by another vehicle before Beck's truck collided with it. The Circuit Court of St. Charles County held a jury trial, which resulted in a verdict awarding the plaintiffs $10,000,000 in compensatory damages, $10,000,000 in aggravating circumstances damages against Great Plains, and $25,000 in aggravating circumstances damages against Beck. The circuit court entered judgment in accordance with the jury's verdicts and awarded post-judgment interest. The defendants filed a post-trial motion for a new trial or judgment notwithstanding the verdict, which the circuit court overruled. The defendants then appealed. The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court found that the defendants did not preserve their claims of error for appellate review or that their preserved claims failed on the merits. Specifically, the court held that the defendants failed to preserve the issue of excluding expert testimony regarding the mother's impairment by THC because they did not object at trial. Additionally, the court found that the defendants did not preserve their objection to the participation of separate counsel for the plaintiffs throughout the trial. The court also held that there was substantial evidence to support the jury's finding that Beck failed to keep a careful lookout and that the jury's award of aggravating circumstances damages against both Beck and Great Plains was supported by sufficient evidence. The court concluded that Beck's multiple violations of the Missouri CDL manual and Great Plains' acceptance of Beck's conduct demonstrated complete indifference or conscious disregard for the safety of others. View "Schultz vs. Great Plains Trucking, Inc." on Justia Law

Le Doux v. Western Express, Inc.

2025-01-23T11:30:21-08:00

Andre Le Doux was driving on Interstate 81 in Virginia when he encountered a sudden traffic standstill due to a torrential downpour. As he braked, a vehicle behind him pushed his van into another vehicle, leaving his van exposed in the left lane. Ervin Worthy, driving a Western Express tractor trailer, saw the heavy rain and braked, but could not stop in time and collided with Le Doux’s van, causing severe injuries to Le Doux. Le Doux sued Worthy for negligence and willful and wanton negligence, and Western Express for vicarious liability and negligent hiring. The United States District Court for the Western District of Virginia excluded expert testimony from Le Doux’s meteorologist and accident reconstructionist due to gaps in radar data and inaccurate GPS timestamps. The court also excluded testimony from Le Doux’s trucking expert, finding it unnecessary for the jury to understand the standard of care for a tractor trailer driver in rainy conditions. Additionally, the court dismissed Le Doux’s negligent hiring claim against Western Express, reasoning that since Worthy was acting within the scope of his employment, the claim was redundant. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of the expert testimonies, agreeing that the gaps in data and potential jury confusion justified the decision. The court also upheld the exclusion of the trucking expert’s testimony, finding that the jury could understand the necessary standard of care without it. Finally, the court affirmed the dismissal of the negligent hiring claim, holding that since the jury found Worthy not negligent, Western Express could not be liable for negligent hiring. The Fourth Circuit concluded that the district court did not abuse its discretion in its rulings. View "Le Doux v. Western Express, Inc." on Justia Law

Sierra Club v. DOT

2025-01-17T08:00:57-08:00

The case involves a challenge to a rule promulgated by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in 2020, which authorized the transportation of liquefied natural gas (LNG) by rail in newly designed tank cars without requiring a permit. LNG is a hazardous material that poses significant risks if released, including explosions, fires, and the formation of ultra-cold gas clouds. The rule did not limit the number of LNG tank cars per train or set a mandatory speed limit, raising safety concerns among various stakeholders. The rule was challenged by a coalition of environmental nonprofits, several states, and the Puyallup Tribe of Indians. They argued that PHMSA did not adequately consider the safety risks and that the National Environmental Policy Act (NEPA) required the preparation of an Environmental Impact Statement (EIS). The petitioners contended that the decision not to prepare an EIS was arbitrary and capricious. The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that PHMSA's decision not to prepare an EIS was indeed arbitrary and capricious. The court noted that transporting LNG by rail poses a low-probability but high-consequence risk of derailment, which could result in catastrophic environmental impacts. The court emphasized that PHMSA failed to adequately consider the probability and potential consequences of such accidents and did not impose sufficient safety measures, such as a mandatory speed limit or a cap on the number of LNG tank cars per train. The court held that PHMSA's failure to prepare an EIS violated NEPA and vacated the LNG Rule, remanding the case to PHMSA for further proceedings. The court's decision underscores the importance of thoroughly assessing environmental risks and adhering to NEPA's requirements in rulemaking processes. View "Sierra Club v. DOT" on Justia Law

City and County of San Francisco v. Public Utilities Commission

2025-01-14T11:31:16-08:00

The City and County of San Francisco and the San Francisco County Transportation Authority challenged a decision by the Public Utilities Commission (PUC) to issue a phase I driverless autonomous vehicle (AV) deployment permit to Waymo, LLC for fared passenger service in San Francisco and parts of San Mateo County. The petitioners argued that the PUC failed to follow the law and disregarded significant public safety issues. However, the record showed that the PUC considered and responded to the safety concerns raised by the petitioners, noting that few incidents involved Waymo driverless AVs, each was minor, and none involved injuries. The PUC had previously issued a decision establishing a pilot program for the regulation of AV passenger carriers, which included both drivered and driverless AVs. The petitioners participated in these proceedings but did not challenge the decision at that time. Waymo submitted an advice letter in December 2022 seeking a phase I driverless AV deployment permit, which was protested by the San Francisco entities. The PUC's Consumer Protection and Enforcement Division circulated a draft resolution authorizing Waymo's permit, and after considering comments and holding meetings, the PUC issued a final resolution in August 2023, authorizing Waymo to provide fared driverless AV service. The California Court of Appeal reviewed the case and found that the PUC acted within its authority and did not abuse its discretion. The court noted that the PUC's decision was supported by substantial evidence, including data showing that Waymo driverless AVs had not been involved in any collisions resulting in injuries. The court also upheld the PUC's use of the advice letter process, as it was authorized by the PUC's prior decision. The court denied the relief requested by the petitioners, affirming the PUC's decision to issue the phase I driverless AV deployment permit to Waymo. View "City and County of San Francisco v. Public Utilities Commission" on Justia Law

Montgomery v. C.H. Robinson Company

2025-01-03T07:30:30-08:00

Shawn Montgomery was severely injured when his truck was hit by a tractor-trailer driven by Yosniel Varela-Mojena, who was employed by motor carrier Caribe Transport II, LLC. The shipment was coordinated by C.H. Robinson Worldwide, Inc., a freight broker. Montgomery sued Varela-Mojena, Caribe, and Robinson, alleging that Robinson negligently hired Varela-Mojena and Caribe and was vicariously liable for their actions. The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of Robinson on the vicarious liability claim, finding that Varela-Mojena and Caribe were independent contractors, not agents of Robinson. Following the Seventh Circuit's decision in Ye v. GlobalTranz Enterprises, Inc., which held that the Federal Aviation Administration Authorization Act (FAAAA) preempts state law claims against freight brokers for negligent hiring, the district court also granted judgment for Robinson on the negligent hiring claims. Final judgment was entered in favor of Robinson to facilitate Montgomery's appeal, while his claims against Varela-Mojena and Caribe were stayed. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that Robinson did not exercise the necessary control over Caribe and Varela-Mojena to establish an agency relationship, thus negating vicarious liability. The court also declined to overrule its precedent in Ye, maintaining that the FAAAA preempts state law negligent hiring claims against freight brokers. Consequently, the court affirmed the district court's judgment in favor of Robinson. View "Montgomery v. C.H. Robinson Company" on Justia Law

Clegg v. American Airlines, Inc.

2024-12-31T08:34:26-08:00

Campbell and Jennie Clegg purchased first-class round-trip tickets from American Airlines for themselves and three family members for travel between Albany, New York, and San Francisco, California, in May 2022. They agreed to American’s Conditions of Carriage, which required check-in at least 45 minutes before departure. The night before their flight, the Cleggs were unable to check in online and were instructed to check in at the airport. They arrived at the airport at 4:47 a.m. for their 6:04 a.m. flight but were unable to check in due to a computer system issue. Consequently, they missed their flight and later found that their return flight was canceled. They did not receive a refund for either flight. The Cleggs filed a complaint in the Cumberland County Superior Court, alleging breach of contract, fraud, and breach of the Maine Unfair Trade Practices Act. The court granted American Airlines' motion for summary judgment, ruling that the Cleggs’ claims were preempted by the Airline Deregulation Act. The Cleggs appealed the decision. The Maine Supreme Judicial Court reviewed the case and vacated the Superior Court's judgment in part. The court held that while the Airline Deregulation Act preempts state law claims related to airline services, the Cleggs could pursue a breach of contract claim based on the Conditions of Carriage. The court determined that the Cleggs might be entitled to a refund for their tickets and any extras, as specified in the Conditions of Carriage. However, the court affirmed that the Cleggs could not recover consequential or punitive damages, attorney fees, or costs, as these were preempted by the Airline Deregulation Act. The case was remanded for further proceedings consistent with this opinion. View "Clegg v. American Airlines, Inc." on Justia Law

Bradshaw v. American Airlines

2024-12-17T08:30:56-08:00

Deborah Bradshaw and Chrystal Antao sued American Airlines and Mesa Airlines, alleging injuries and damages from the airlines' negligent handling of an in-flight emergency. During a June 2020 flight, the aircraft experienced a malfunction that led to a loss of cabin pressure, requiring an emergency descent. The plaintiffs claimed the pilot failed to properly inform passengers of the threat and descended too rapidly, while American Airlines failed to provide medical personnel upon landing. The case was initially filed in the District Court of Tulsa County, Oklahoma, and later removed to the United States District Court for the Northern District of Oklahoma on diversity grounds. The district court granted summary judgment in favor of the airlines, concluding that federal law preempted Oklahoma's common-carrier standard of care in aviation safety. The court allowed the plaintiffs to pursue a state negligence claim using the federal "reckless-or-careless manner" standard but found no evidence that the airlines violated this standard. The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that the Federal Aviation Act and related regulations preempt state law in the field of aviation safety. The court agreed that the federal "careless or reckless manner" standard of care applies, preempting Oklahoma's common-carrier standard. The court found no genuine issue of material fact regarding a violation of federal regulations by the airlines and upheld the summary judgment in favor of the defendants. View "Bradshaw v. American Airlines" on Justia Law

Agency of Transportation v. Timberlake Associates, LLC

2024-12-13T07:11:34-08:00

The Vermont Agency of Transportation (AOT) proposed a project to reconstruct the interchange between Interstate 89 and U.S. Routes 2 and 7 in Colchester, Vermont, into a Diverging Diamond Interchange (DDI). Timberlake Associates, LLP, the landowner of a gas station at the southeast corner of the interchange, contested the necessity of the land takings required for the project. Timberlake argued that AOT did not fulfill its pre-suit obligation to negotiate and that the trial court erred in its determination of necessity. The Superior Court, Chittenden Unit, Civil Division, held a four-day evidentiary hearing and concluded that Timberlake failed to demonstrate bad faith or abuse of discretion by AOT. The court found that AOT had satisfied its burden of demonstrating the necessity of taking Timberlake’s property to the extent proposed. Timberlake appealed the decision, arguing that AOT did not adequately consider the statutory factors of necessity and failed to negotiate in good faith. The Vermont Supreme Court reviewed the case and affirmed the lower court’s decision. The Court found that AOT presented sufficient evidence showing it considered the statutory factors, including the adequacy of other property and locations, the effect on the landowner’s convenience, and the environmental impacts. The Court also determined that AOT’s selection of the DDI design was justified based on its superior performance in increasing capacity, reducing congestion, and improving safety compared to other alternatives. Additionally, the Court concluded that AOT made reasonable efforts to negotiate with Timberlake before filing suit, as required by statute. The Vermont Supreme Court held that the trial court acted within its discretion in determining the necessity of the takings and that AOT fulfilled its pre-suit obligation to negotiate. The decision of the lower court was affirmed. View "Agency of Transportation v. Timberlake Associates, LLC" on Justia Law

Blazer v. Department of Public Safety

2024-12-12T08:11:00-08:00

Donald Blazer was involved in a vehicle accident and voluntarily submitted to a preliminary breath test (PBT), which showed a blood alcohol content of .102 percent. However, he refused to submit to a blood draw. The South Dakota Department of Public Safety (Department) notified Blazer of its intent to disqualify his commercial driver’s license (CDL) for life, citing this refusal as a second violation of SDCL 32-12A-36, with the first being a 2014 DUI conviction. Blazer requested an administrative hearing, and the Department affirmed the disqualification of his CDL for life. Blazer appealed to the circuit court, which reversed the Department’s decision. The circuit court concluded that Blazer’s voluntary submission to the breath test constituted a submission to a chemical analysis, meaning his refusal to submit to the blood draw could not result in the disqualification of his CDL. The Department then appealed to the South Dakota Supreme Court. The South Dakota Supreme Court reviewed the case and reversed the circuit court’s decision. The Court held that under SDCL 32-23-1.2, a preliminary breath test (PBT) is permitted and may be required in addition to a chemical test. The Court determined that Blazer’s refusal to submit to the blood draw constituted a refusal to submit to a chemical analysis as required by SDCL 32-12A-46. This refusal was a second violation under SDCL 32-12A-36, justifying the disqualification of Blazer’s CDL for life under SDCL 32-12A-37. The Court emphasized that a PBT is a preliminary test and does not fulfill the requirement for a chemical analysis under the implied consent laws. View "Blazer v. Department of Public Safety" on Justia Law

Wisconsin Central Ltd. v. Surface Transportation Board

2024-12-11T15:00:20-08:00

Wisconsin Central Ltd. and Soo Line Railroad Company are in dispute over the location for exchanging rail traffic in the Chicago area. Wisconsin Central prefers the Belt Railway yard near Chicago, while Soo Line prefers the Spaulding yard near Bartlett, 35 miles away. The Surface Transportation Board initially ruled against Wisconsin Central, stating that it could not use Belt Railway's yard because it did not own it outright, despite having a contractual right to use it. The Seventh Circuit Court of Appeals remanded the case, clarifying that a railroad could have the power to designate facilities by contract as well as by ownership. Upon remand, the Surface Transportation Board held that the Belt Railway yard was not a reasonable location for the exchange. The Board found that both locations could cause congestion but concluded that it was unreasonable for Wisconsin Central to insist that Soo Line bear the costs of moving cars to Chicago and the fees charged by Belt Railway. Additionally, the Board emphasized the importance of negotiation and agreement in selecting exchange locations, rather than allowing one party to unilaterally change the location. The United States Court of Appeals for the Seventh Circuit reviewed the Board's decision. The court held that the Board's interpretation of "reasonable" was within its discretion and that considering costs as part of reasonableness was appropriate. The court also noted that Wisconsin Central did not preserve its argument regarding substantial evidence for review. Consequently, the court found that the Board's decision was neither arbitrary nor capricious and did not embody a legal error. The petition for review was denied. View "Wisconsin Central Ltd. v. Surface Transportation Board" on Justia Law

Bahreman v. Allegiant Air, LLC

2024-12-10T09:30:27-08:00

Ali Bahreman, a flight attendant for Allegiant Air, challenged the Collective Bargaining Agreement (CBA) between Allegiant and the Transport Workers Union (Union). The CBA required employees to either pay union dues or agency fees to maintain seniority-based bidding privileges for work schedules. Bahreman chose not to pay any fees and subsequently lost his bidding privileges. He argued that this arrangement violated the Railway Labor Act (RLA) by coercing employees to join the Union, deviating from the employment-termination remedy, and breaching the Union's duty of fair representation. The United States District Court for the District of Nevada granted summary judgment in favor of Allegiant and the Union. The court found that the CBA did not violate the RLA's anti-coercion provision, as it did not induce employees to join the Union. The court also held that the RLA does not prohibit collective bargaining agreements with terms other than those explicitly permitted by the Act. Additionally, the court determined that the Union did not breach its duty of fair representation, as it enforced the CBA equally among all members of the bargaining unit. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the RLA does not prohibit a collective bargaining agreement that conditions seniority-based bidding privileges on the payment of union dues or agency fees. The court found that the CBA did not induce union membership, as it treated union members and nonmembers alike regarding payment requirements. The court also concluded that the CBA's terms were permissible under the RLA and that the Union did not act arbitrarily, discriminatorily, or in bad faith in enforcing the agreement. View "Bahreman v. Allegiant Air, LLC" on Justia Law

American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority

2024-12-06T14:30:04-08:00

In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges. The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause. The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges. The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law

Malco Enterprises of Nevada, Inc. vs. Woldeyohannes

2024-12-05T10:11:42-08:00

Sky Moore rented a car from Budget Car and Truck Rental of Las Vegas, owned by Malco Enterprises of Nevada, Inc. Sky named Daniel Moore as an additional driver, who later rear-ended Alelign Woldeyohannes while intoxicated. Alelign sued Daniel for negligence and Malco for negligent entrustment. Daniel did not respond, resulting in a default judgment against him. The case proceeded to arbitration, where Alelign was awarded $32,680.26. Malco requested a trial de novo, leading to a short trial where the judge entered a default judgment against Daniel for $37,886.82. Alelign moved to apply the default judgment against Malco under NRS 482.305(1), which holds short-term lessors liable for damages if they fail to provide minimum insurance coverage. Malco opposed, arguing that NRS 482.305 is preempted by the Graves Amendment, which prohibits states from holding vehicle lessors vicariously liable without negligence or wrongdoing. The short trial judge granted Alelign’s motion, and the district court affirmed, concluding that NRS 482.305 is a financial responsibility law preserved by the Graves Amendment’s savings clause. The Supreme Court of Nevada reviewed the case and affirmed the district court’s judgment. The court held that NRS 482.305 is not preempted by the Graves Amendment because it is a financial responsibility law preserved by the savings clause under 49 U.S.C. § 30106(b). The court emphasized that NRS 482.305 imposes a legal requirement for lessors to provide minimum coverage, rather than a mere financial inducement, and does not impose strict vicarious liability on lessors. View "Malco Enterprises of Nevada, Inc. vs. Woldeyohannes" on Justia Law

Brock v. Flowers Foods

2024-11-12T08:00:58-08:00

Angelo Brock, an independent distributor for Flowers Baking Co. of Denver, LLC, filed a class-action lawsuit alleging wage and hour violations under the Fair Labor Standards Act and Colorado labor law. Brock claimed that Flowers misclassified its delivery drivers as independent contractors to avoid paying proper wages. Flowers moved to compel arbitration based on an Arbitration Agreement within the Distributor Agreement between Brock and Flowers. The district court denied the motion, leading to this appeal. The United States District Court for the District of Colorado found that Brock fell within the "transportation workers exemption" under § 1 of the Federal Arbitration Act (FAA), which exempts certain transportation workers from arbitration. The court concluded that Brock's class of workers, who deliver Flowers goods intrastate, are engaged in interstate commerce because they play a direct and necessary role in the flow of goods across state lines. The court also determined that the Arbitration Agreement did not allow for arbitration under Colorado law, as it was inconsistent with the FAA. The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The Tenth Circuit agreed that Brock's class of workers is engaged in interstate commerce, as their intrastate deliveries are part of a continuous interstate journey of goods. The court found that Flowers retains significant control over Brock's operations, indicating that the goods' delivery to retail stores is the final leg of an interstate route. The court declined to review Flowers's argument that the Distributor Agreement is not a contract of employment, as it was not raised in the lower court. Additionally, the court determined it lacked jurisdiction to review the district court's denial of arbitration under Colorado law. View "Brock v. Flowers Foods" on Justia Law

Stribling Equipment, LLC v. Eason Propane, LLC

2024-10-18T01:21:17-08:00

Eason Propane, LLC, purchased a new Freightliner propane delivery truck, which caught fire due to Empire Truck Sales, LLC's negligence during repairs. The fire caused significant damage to the truck, leading to extensive business losses for Eason Propane. Eason Propane sued Empire, seeking damages for the truck's diminished value, repair costs, lost profits, and other consequential damages. The case was tried in the Lamar County Circuit Court, where the jury found Empire liable and awarded Eason Propane $263,443.39 in damages. Empire moved for a new trial on damages or a remittitur, arguing that the jury's award was against the overwhelming weight of the evidence. The trial court denied Empire's motion, leading to this appeal. The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decision. The court held that the jury's damages award was not manifestly unjust or so excessive as to shock the conscience. The court found that the evidence presented at trial supported the jury's findings, including the testimony of Eason Propane's experts regarding the truck's diminished value and lost profits. The court emphasized that it was within the jury's purview to weigh the credibility of the competing testimonies and evidence. The court concluded that the trial court did not abuse its discretion in denying Empire's motion for a new trial or remittitur. The jury's award of $112,698.46 for the truck's diminished value, $24,744.93 for repair costs, $120,000 for lost profits, and $6,000 for other consequential damages was affirmed. View "Stribling Equipment, LLC v. Eason Propane, LLC" on Justia Law

WATSON v. BNSF RAILWAY COMPANY

2024-10-15T08:13:12-08:00

In August 2014, a train operated by BNSF Railway Company collided with a pickup truck driven by Paul Watson at a railroad crossing in Pawnee County, Oklahoma. Watson, who was not wearing a seatbelt, died instantly, while his wife Terri and their minor child, both belted, survived with injuries. Terri Watson, on behalf of herself, her child, and as a representative of her deceased husband's estate, filed a wrongful death and personal injury lawsuit against BNSF, alleging negligent maintenance of the crossing and failure to install adequate safety features. The case went to trial, and after three weeks of testimony and evidence, the jury found in favor of BNSF on all claims. The plaintiffs' motion for a new trial was denied by the trial court. On appeal, the Court of Civil Appeals, Division IV, found prejudicial errors in the jury instructions, specifically noting that the instructions were biased in favor of BNSF and required an excessive degree of care from Watson. The appellate court reversed the trial court's decision and remanded the case for a new trial. The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The court found that the jury instructions, when considered as a whole, were not so prejudicial as to mislead the jury. The court noted that the instructions accurately reflected Oklahoma law and did not impose a higher standard of care on Watson than required. Consequently, the Supreme Court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's judgment, and reinstated the jury's verdict in favor of BNSF. The case was remanded for further proceedings consistent with this opinion. View "WATSON v. BNSF RAILWAY COMPANY" on Justia Law

Bonnet v. Whitaker

2024-09-25T13:30:04-08:00

Two pilots, Luis F. Bonnet and Carlos R. Benítez Maldonado, were employed by Benítez Aviation, Inc. (BAI), which managed a Cessna aircraft. In April and May 2019, Bonnet and Benítez piloted several flights without the required certificates for commercial operations. The FAA suspended their Airline Transport Pilot (ATP) certificates for 270 days, alleging they operated the flights as air carriers or commercial operators without proper certification. The pilots received their regular salaries but no additional compensation for these flights. The FAA issued a Notice of Proposed Certificate Action, which the pilots appealed to the National Transportation Safety Board (NTSB). An administrative law judge (ALJ) upheld the FAA's suspension order, finding that the flights were conducted for compensation and hire, thus requiring compliance with Part 135 regulations. The NTSB affirmed the ALJ's decision, concluding that the flights were subject to air carrier or commercial operator requirements and that the pilots violated multiple FAA regulations. The NTSB also found that the ALJ did not exhibit bias and that the 270-day suspension was appropriate. The United States Court of Appeals for the First Circuit reviewed the case. The court held that substantial evidence supported the NTSB's findings that the flights were operated as common carriers for compensation, thus requiring Part 135 certification. The court also found that the pilots were responsible for ensuring compliance with FAA regulations, regardless of BAI's role in booking the flights. The court upheld the NTSB's decision, including the 270-day suspension of the pilots' certificates, finding it justified based on the pilots' regulatory violations and the potential risk to passenger safety. The petition for review was denied. View "Bonnet v. Whitaker" on Justia Law

MENDOCINO RAILWAY V. AINSWORTH

2024-08-29T08:30:52-08:00

Mendocino Railway, a California corporation, owns and operates a railroad line known as the "Skunk Train" between Fort Bragg and Willits, California. The City of Fort Bragg and the California Coastal Commission sought to regulate the use and maintenance of the Railway's properties within the City, which the Railway resisted, claiming federal preemption under the Interstate Commerce Commission Termination Act (ICCTA). The City filed a state court action seeking declaratory and injunctive relief to compel the Railway to comply with local regulations. The Railway argued that federal law preempted these local regulations. Subsequently, the Railway filed a federal lawsuit seeking a declaration that the City's and Commission's regulatory actions were preempted by federal law and an injunction to prevent interference with its operations. The Mendocino County Superior Court overruled the Railway's demurrer, which argued that federal law preempted all local regulations. The Railway's subsequent petitions to the California Court of Appeal and the California Supreme Court were unsuccessful. The Railway then filed an answer in the state court, asserting federal preemption as an affirmative defense. Meanwhile, the Commission intervened in the state court action, seeking a declaration that the Coastal Act and local coastal program applied to the Railway's activities and were not preempted by federal law. The Railway also attempted to remove the state action to federal court, but the district court remanded it back to state court. The United States Court of Appeals for the Ninth Circuit reviewed the district court's dismissal of the Railway's federal lawsuit under the Colorado River doctrine, which allows federal courts to abstain from exercising jurisdiction in favor of parallel state court proceedings. The Ninth Circuit affirmed the district court's dismissal, finding that the state court proceedings were sufficiently parallel to the federal action and that considerations of avoiding piecemeal litigation, forum shopping, and the order in which the forums obtained jurisdiction supported the dismissal. The court held that the state court could adequately protect the Railway's rights and that the federal preemption issue could be resolved in the state court proceedings. View "MENDOCINO RAILWAY V. AINSWORTH" on Justia Law

Hardy v. Scandinavian Airline System

2024-08-26T15:30:15-08:00

Susan Hardy, a resident of Louisiana, flew from Newark, New Jersey, to Oslo, Norway, on Scandinavian Airlines System (SAS). Upon disembarking in Oslo, she fell and fractured her leg. Hardy sued SAS in the Eastern District of Louisiana, claiming that Article 33 of the Montreal Convention provided both subject matter and personal jurisdiction over SAS. The district court dismissed her case, ruling that the Montreal Convention only granted subject matter jurisdiction and not personal jurisdiction. Additionally, the court found that SAS’s waiver of service did not establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2). The United States District Court for the Eastern District of Louisiana dismissed Hardy’s complaint without prejudice. The court concluded that Article 33 of the Montreal Convention did not create personal jurisdiction over SAS. It also rejected Hardy’s argument that SAS’s waiver of service under Federal Rule of Civil Procedure 4(k)(2) established personal jurisdiction, reasoning that SAS did not have sufficient contacts with Louisiana to warrant such jurisdiction. The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Article 33 of the Montreal Convention does not independently create personal jurisdiction over a defendant airline, as it only prescribes venue. However, the court found that the district court erred in its analysis under Rule 4(k)(2). The correct analysis should have considered SAS’s contacts with the United States as a whole, not just Louisiana. The Fifth Circuit concluded that SAS had sufficient minimum contacts with the United States to establish personal jurisdiction under Rule 4(k)(2). Consequently, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "Hardy v. Scandinavian Airline System" on Justia Law

Union Pacific Railroad Co. v. STB

2024-08-20T07:30:21-08:00

Union Pacific Railroad Company and the Association of American Railroads challenged the Surface Transportation Board's (Board) adoption of the Final Offer Rate Review (FORR) procedure for determining the reasonableness of rail carrier rates in smaller cases. Under FORR, the Board selects either the shipper’s or the rail carrier’s final offer without modification. The petitioners argued that the Board lacked statutory authority to implement FORR, that FORR was unconstitutionally vague, and that it was arbitrary and capricious. The Board is tasked with resolving rate disputes between rail carriers and shippers when rates are not set by private contract. The Board must hold a "full hearing" and give due consideration to specific statutory factors before determining the reasonableness of a rate. The Board adopted FORR to streamline the process for smaller disputes, allowing it to choose between the final offers submitted by the parties. The United States Court of Appeals for the Eighth Circuit reviewed whether the Board had statutory authority to implement FORR. The court concluded that FORR conflicted with the Board’s statutory duties. The court held that the Board must hold a "full hearing" and that the shipper must bear the burden of proof on the final offer, which FORR did not require. Additionally, the court found that FORR improperly limited the Board’s ability to prescribe the maximum rate, as required by statute, by forcing the Board to choose between the parties' final offers without modification. The Eighth Circuit granted the petitions for review and vacated the final rule, holding that the Board lacked statutory authority to implement FORR. View "Union Pacific Railroad Co. v. STB" on Justia Law

Bold v. Commonwealth

2024-08-20T07:08:11-08:00

Thomas E. Bold, Jr. was found unconscious behind the wheel of his legally parked car in a mall parking lot. The car's engine was running, and the headlights were on. When roused by Officer Thomas Gelnett, Bold appeared intoxicated and admitted to drinking at a nearby bar. He intended to sleep in his car until he was fit to drive. Bold was arrested for DUI and refused a blood test at a medical facility. Consequently, PennDOT suspended his license for 18 months due to his refusal. Bold appealed the suspension in the Cumberland County Court of Common Pleas. During the hearing, Officer Gelnett admitted there was no evidence that Bold had driven the car while intoxicated. The court initially upheld the suspension but later reversed its decision, finding no reasonable grounds to believe Bold was in control of the vehicle's movement. The court cited the case Solomon v. PennDOT, which found insufficient grounds for suspicion when a suspect was found sleeping in a parked car with the engine running. The Commonwealth Court reversed the trial court's decision, holding that the officer had reasonable grounds to believe Bold was in actual physical control of the vehicle. The court relied on past cases where the presence of a driver in a running vehicle was deemed sufficient for reasonable grounds. However, the Supreme Court of Pennsylvania found that the circumstances did not provide reasonable grounds to believe Bold was operating or in actual physical control of the vehicle's movement. The court emphasized that the implied consent law requires some objective evidence of control over the vehicle's movement. Consequently, the Supreme Court reversed the Commonwealth Court's ruling, siding with Bold. View "Bold v. Commonwealth" on Justia Law

Parker v. BNSF Railway Co.

2024-08-09T08:31:09-08:00

Curtis Rookaird, represented by Paul Parker, was terminated by BNSF Railway Company after performing an air-brake test, which he argued was a protected activity under the Federal Railroad Safety Act (FRSA). Rookaird claimed his termination was retaliatory. Initially, a jury found in Rookaird’s favor, but the Ninth Circuit vacated the verdict and remanded the case to the district court to reconsider whether the air-brake test contributed to BNSF’s decision to terminate him. On remand, the district court conducted a bench trial and ruled in favor of BNSF, concluding that while the air-brake test contributed to the termination, it did so "very little." The district court found that BNSF had conceded the air-brake test contributed to Rookaird’s termination but ruled that BNSF was entitled to an affirmative defense by showing the test contributed minimally. The court also upheld BNSF’s evidentiary rulings, excluding certain testimony and admitting comparator evidence. Rookaird appealed, arguing the district court misapplied the FRSA and erred in its evidentiary rulings. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s evidentiary rulings, finding no abuse of discretion. However, it vacated the district court’s judgment on the affirmative defense issue. The Ninth Circuit held that under the FRSA, an employer must prove by clear and convincing evidence that it would have terminated the employee absent the protected activity, not merely that the protected activity contributed "very little" to the decision. The case was remanded for the district court to determine if BNSF met this burden, given that the air-brake test could not contribute even in part to the termination decision. View "Parker v. BNSF Railway Co." on Justia Law

Kelley v. Alpine Site Services

2024-08-08T15:30:17-08:00

The plaintiffs, former employees of Alpine Site Services, Inc., filed a lawsuit alleging that the company violated the Fair Labor Standards Act (FLSA) by failing to pay them the required overtime wages. Alpine contended that the Motor Carrier Act (MCA) exemption applied, which would exempt them from paying overtime. The plaintiffs argued that they were not properly classified under the MCA exemption. The United States District Court for the Southern District of Texas reviewed the case and agreed with Alpine, finding that the plaintiffs were classified as "loaders" under the MCA exemption. The court found that the plaintiffs' job duties included loading vehicles, which directly affected the safety of operation of motor vehicles in interstate commerce. The district court dismissed the suit with prejudice, concluding that the plaintiffs fell under the MCA exemption and were not entitled to overtime pay. The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not err in classifying the plaintiffs as "loaders" under the MCA exemption. The court noted that the plaintiffs' duties included loading vehicles, which required the exercise of judgment and discretion, and that this work directly affected the safety of operation of motor vehicles. The court also found that the plaintiffs regularly engaged in loading activities, which constituted a substantial part of their job responsibilities. The appellate court concluded that the MCA exemption applied to the plaintiffs in all workweeks, even those in which they performed only non-safety-affecting duties. The court also dismissed the plaintiffs' claim that the district court abused its discretion in denying their motion to amend the court's factual findings, as the plaintiffs failed to provide meaningful analysis or supporting authority for this argument. The decision of the district court was affirmed. View "Kelley v. Alpine Site Services" on Justia Law

United States v. Yanjun Xu

2024-08-07T12:00:33-08:00

Yanjun Xu, a Chinese citizen and member of China’s Ministry of State Security, was convicted of conspiracy to commit economic espionage and conspiracy to steal trade secrets from multiple aviation companies over a five-year period. Xu was also convicted of attempted economic espionage by theft or fraud and attempted theft of composite fan-blade technology from GE Aviation. He was sentenced to a combined 240 months’ imprisonment. Xu appealed, seeking to vacate the judgment and remand for a new trial, arguing that the district court erred in failing to dismiss Counts 1 and 2 as duplicitous and abused its discretion in admitting expert testimony in violation of Federal Rule of Evidence 704(b). Alternatively, Xu sought to have his sentence vacated, arguing it was both procedurally and substantively unreasonable. The United States District Court for the Southern District of Ohio denied Xu’s motion to dismiss the indictment, finding that the conspiracy counts were not duplicitous as they alleged a single overarching conspiracy. The court also admitted expert testimony from James Olson, a retired CIA officer, who testified about espionage techniques and tradecraft, which Xu argued violated Rule 704(b). The court overruled Xu’s objections, finding that Olson’s testimony did not directly opine on Xu’s intent but rather described common practices in espionage. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the indictment was not duplicitous as it charged a single conspiracy with multiple overt acts. The court also found that Olson’s testimony did not violate Rule 704(b) and that any potential error was cured by the district court’s limiting instructions to the jury. Additionally, the appellate court found Xu’s sentence to be procedurally and substantively reasonable, noting that the district court properly calculated the intended loss and considered the § 3553(a) factors. The court concluded that Xu’s sentence was within the Guidelines range and not disparate compared to similarly situated defendants. View "United States v. Yanjun Xu" on Justia Law

Carson v. USAA Casualty Insurance

2024-08-06T15:30:18-08:00

In 2021, Shannon Carson was injured in an automobile accident in Louisiana while driving an 18-wheeler truck owned by his employer. The accident was caused by another driver, Jamarcea Washington, who was insured by GEICO and died in the collision. Carson's employer's truck was insured by American Millenium Insurance Company, which provided $75,000 in underinsured motorist (UIM) coverage. Carson also had a personal automobile insurance policy with USAA, which provided $50,000 in UIM coverage. Carson settled with GEICO and American Millenium for their policy limits and then sought additional UIM benefits from his USAA policy. The case was initially filed in Louisiana state court and then removed to the United States District Court for the Western District of Louisiana based on diversity jurisdiction. The district court granted summary judgment in favor of USAA, concluding that Carson, as a Class II insured under South Carolina law, was prohibited from stacking his personal UIM insurance on top of the American Millenium UIM coverage. Carson filed a Rule 59(e) motion, arguing that he was entitled to "port" his personal UIM coverage under South Carolina law. The district court denied the motion, maintaining that the case involved stacking, not portability, and that Carson had already received the statutory limit for UIM coverage. The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court concluded that South Carolina law does not prevent Carson from recovering UIM benefits under his personal automobile insurance policy with USAA. The court distinguished between stacking and portability, noting that while stacking is prohibited for Class II insureds, portability allows an insured to recover under their personal UIM policy when their vehicle is not involved in the accident. The court vacated the district court's summary judgment and remanded the case for further proceedings consistent with its opinion. View "Carson v. USAA Casualty Insurance" on Justia Law

Buehler v. Boeing Company

2024-08-06T13:00:18-08:00

The case involves the crash of Lion Air Flight JT 610, a Boeing 737 MAX, which took off from Jakarta, Indonesia, and crashed into the Java Sea on October 29, 2018, killing all on board. The plaintiffs are family members and representatives of the estates of two passengers, Liu Chandra and Andrea Manfredi. They filed lawsuits against Boeing and other defendants, seeking damages under various legal theories, including the Death on the High Seas Act (DOHSA), state law, and other federal statutes. The Chandra case was initially filed in Illinois state court and then removed to the United States District Court for the Northern District of Illinois. The Manfredi case was filed directly in the same federal court. Both sets of plaintiffs demanded a jury trial and asserted claims under DOHSA, state law, and other federal statutes. Boeing filed motions to limit the plaintiffs' claims to DOHSA and to preclude a jury trial. The district court ruled in favor of Boeing, holding that DOHSA was the exclusive remedy and that the plaintiffs were not entitled to a jury trial. The court dismissed all non-DOHSA claims and certified the jury trial issue for interlocutory appeal. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's rulings, holding that DOHSA preempts all other claims and mandates a bench trial. The court reasoned that DOHSA's language and legislative history indicate that claims under the statute must be brought in admiralty, which does not carry the right to a jury trial. The court also noted that Congress has not amended DOHSA to allow for jury trials in federal court, despite longstanding judicial interpretations to the contrary. Therefore, the plaintiffs' claims must proceed without a jury. The court's decision was to affirm the district court's rulings. View "Buehler v. Boeing Company" on Justia Law

Lupia v. New Jersey Transit Rail Operations, Inc.

2024-08-01T06:30:06-08:00

Scott Lupia, a locomotive engineer for New Jersey Transit Rail Operations, Inc. (NJT), was injured when the air conditioning (A/C) unit in his cab malfunctioned, causing the temperature to rise to 114 degrees Fahrenheit. Despite notifying his supervisors, Lupia was instructed to operate the train, leading to his collapse from heat exhaustion and subsequent permanent injuries. Lupia filed a lawsuit under the Federal Employers’ Liability Act (FELA), alleging that NJT violated the Locomotive Inspection Act (LIA) by failing to maintain the locomotive's parts and appurtenances, including the A/C unit, in safe operating condition. The United States District Court for the Southern District of New York denied NJT's motion for summary judgment, holding that a temperature control system, including an A/C unit, is considered a "part and appurtenance" of a locomotive under the LIA. The court found sufficient evidence that NJT's failure to maintain the A/C unit in proper condition posed an unnecessary danger of personal injury. During the trial, the court allowed Lupia to introduce a report to impeach NJT’s witness and permitted arguments regarding noneconomic damages. The jury awarded Lupia significant damages for lost earnings and pain and suffering. The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the District Court's judgment. The appellate court agreed that a temperature control system is an integral part of a locomotive and that NJT was required to maintain the A/C unit in safe operating condition once it chose to use it as part of its temperature control system. The court also found no abuse of discretion in the District Court's evidentiary rulings and its decision to allow arguments on noneconomic damages. View "Lupia v. New Jersey Transit Rail Operations, Inc." on Justia Law

Airlines for America v. Department of Transportation

2024-07-29T16:30:13-08:00

The Department of Transportation (DOT) issued a Rule on April 30, 2024, requiring airlines to disclose ancillary service fees, such as baggage and change fees, during the booking process. The Rule aims to protect consumers from surprise charges and is expected to provide significant societal and consumer benefits. The Rule took effect on July 1, 2024, with compliance deadlines for airlines and third-party ticket agents set for later dates. Various airlines and airline associations challenged the Rule, arguing it exceeds DOT’s authority, is arbitrary and capricious, and bypassed the required notice and comment process. The airlines and associations first sought a stay from the DOT, which was denied. They then petitioned the United States Court of Appeals for the Fifth Circuit for a stay pending review. The petitioners argued that the Rule exceeds DOT’s statutory authority under 49 U.S.C. § 41712(a), which allows the DOT Secretary to investigate and adjudicate unfair or deceptive practices but does not authorize the creation of detailed legislative rules. The petitioners also claimed that the Rule imposes significant compliance costs that would cause irreparable harm. The United States Court of Appeals for the Fifth Circuit granted the stay, finding that the petitioners made a strong showing that the Rule likely exceeds DOT’s authority. The court noted that the Rule mandates specific disclosure practices without the adjudicatory process required by the statute. The court also found that the petitioners would suffer irreparable harm due to the nonrecoverable compliance costs. The court concluded that there is no public interest in perpetuating unlawful agency action and expedited the petition for review to the next available oral argument panel. View "Airlines for America v. Department of Transportation" on Justia Law