Justia Government & Administrative Law Opinion Summaries

A municipal corporation operating a large regional commuter rail system in the Chicago area provided rail service on lines owned by a freight rail company. For decades, this service was conducted under a series of agreements, but in 2019, the freight rail company announced it would cease operating the commuter trains. Following litigation, the freight company obtained a declaratory judgment that it had no ongoing obligation to provide such service. While the commuter rail operator began transitioning to run the service itself, the parties failed to reach agreement on compensation for continued use of the lines. With no long-term agreement in place and negotiations at an impasse, the commuter rail operator applied to the federal Surface Transportation Board for terminal trackage rights, which would allow it to use the lines despite the lack of agreement.The Surface Transportation Board granted the application, finding the lines to be terminal facilities for a reasonable distance from the terminal, and that the use would be practicable, in the public interest, and not substantially impair the freight carrier’s operations. The Board did not set compensation or use conditions at that time but pledged to do so retroactively if the parties could not agree. The freight rail company sought review of this decision in the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit held that the Board acted within its statutory authority in granting terminal trackage rights to the commuter operator, including over the full extent of the lines at issue, and properly concluded the public interest was served. However, the court found that the Board erred by granting immediate rights without first ensuring that compensation was paid or adequately secured, as required by statute. The court vacated the Board’s order and remanded for further proceedings, allowing time for the parties to address compensation. View "Union Pacific Railroad Company v. STB" on Justia Law

Delta Air Lines, Inc. and Aerovias de México, S.A. de C.V. sought approval from the U.S. Department of Transportation (DOT) for a joint venture to provide integrated airline services between the United States and Mexico. DOT approved the joint venture in 2016, granting both approval and antitrust immunity after finding that it would increase competition and public benefits in the U.S.–Mexico aviation market. As part of the approval, DOT required the petitioners to divest certain take-off and landing slots at Mexico City’s airport and imposed a five-year limit on antitrust immunity, citing concerns about slot allocation practices at that airport.After the initial approval, the petitioners operated under these conditions and, in 2022, sought renewal of the joint venture’s approval and immunity. However, DOT issued show-cause orders in 2024, and subsequently a final order in 2025, terminating both the approval and antitrust immunity. The DOT’s decision was based primarily on changes to slot allocation and restrictions on all-cargo carriers by the Mexican government at Mexico City’s airport, which DOT concluded had undermined competition and the public interest. The petitioners challenged this final order in the United States Court of Appeals for the Eleventh Circuit, arguing that DOT’s decision was arbitrary and capricious.The Eleventh Circuit agreed with the petitioners. It found that DOT had departed from its uniform practice of conducting comprehensive market analyses, instead focusing narrowly on a single airport without adequate explanation. The court also determined that DOT had imposed a requirement for open skies agreement implementation on the petitioners that it had not imposed in similar cases involving other countries. The court held that DOT’s final order was arbitrary and capricious, and vacated the order. View "Delta Air Lines, Inc. v. U.S. Department of Transportation" on Justia Law

A pilot was selected for a random drug test at work and tested positive for amphetamine, a prohibited substance under federal aviation regulations. He was immediately grounded by his employer but later reinstated after completing a return-to-duty process. The pilot explained that he had inadvertently ingested his son’s prescription medication, Vyvanse, mistaking it for his own, due to a stressful family medical emergency and similar-looking pill bottles. The Federal Aviation Administration (FAA) initiated proceedings to revoke his pilot and medical certificates, as such a violation typically warrants revocation.The case was first heard by an Administrative Law Judge (ALJ), who found that the pilot had violated the regulations but reduced the sanction from revocation to a 90-day suspension, citing mitigating circumstances. Both parties appealed. The National Transportation Safety Board (NTSB) reviewed the case de novo, concluded the pilot had proven his accidental-ingestion defense by a preponderance of the evidence, and upheld the 90-day suspension. The NTSB found aggravating factors as well, including the pilot’s failure to report the ingestion before performing safety-sensitive duties.The pilot then sought attorney’s fees and expenses under the Equal Access to Justice Act (EAJA), arguing that he was the prevailing party. An ALJ granted his application, but the NTSB reversed, concluding that although the pilot prevailed in obtaining a reduced sanction, the FAA’s position in seeking revocation was substantially justified. On review, the United States Court of Appeals for the District of Columbia Circuit held that the NTSB’s decision was supported by substantial evidence. The court denied the petition for review, holding that the FAA’s actions throughout the proceedings had a reasonable basis in law and fact. View "Knight v. NTSB" on Justia Law

Several railroads and industry groups challenged a federal regulation requiring most freight trains to operate with at least two crewmembers unless the use of a one-person crew is shown to be equally safe. The regulation, issued by the Federal Railroad Administration (FRA) in 2024, responded to safety concerns about the reduction of train crew sizes as technology advanced, citing specific accidents and research on the importance of crew redundancy for safety. The rule provides exemptions for smaller railroads with established one-person operations and offers a special approval process for others, especially those transporting hazardous materials.Previously, the FRA had declined to regulate crew size, withdrawing a proposed rule in 2019 based on insufficient evidence that one-person crews were less safe. However, the U.S. Court of Appeals for the Ninth Circuit vacated this withdrawal, criticizing the agency's reasoning and its attempt to preempt state crew-size laws. Following a new rulemaking process, the FRA finalized the 2024 regulation after considering thousands of public comments, a public hearing, and new safety data.The United States Court of Appeals for the Eleventh Circuit reviewed consolidated petitions from several railroads and associations. The petitioners argued, among other points, that the FRA exceeded its authority, acted arbitrarily and capriciously, failed to adequately consider costs, and violated statutory deadlines. The Eleventh Circuit held that the FRA acted within its broad statutory authority to regulate railroad safety, provided reasonable explanations for its policy changes and regulatory choices, adequately considered evidence and public input, and did not violate the law by taking more than twelve months to finalize the rule. The court denied all petitions for review, upholding the Crew Size Rule. View "Florida East Coast Railway LLC v. Federal Railroad Administration" on Justia Law

The case concerns a challenge to a Colorado statute enacted in 2024, which imposed a “congestion impact fee” of up to $3 per day on all short-term vehicle rentals in the state, including rentals at airports and elsewhere. The fee revenue is designated for transportation infrastructure projects to reduce traffic congestion and benefit users of rental vehicles. The statute specifies that the fee applies to all short-term vehicle rentals statewide, including both traditional rental companies and car-sharing programs.The American Car Rental Association, representing car rental companies operating in Colorado, brought suit in the United States District Court for the District of Colorado. The Association argued that the Colorado fee was preempted by the federal Anti-Head Tax Act (“AHTA”), specifically 49 U.S.C. § 40116(d)(2)(A)(v), which prohibits states from imposing certain taxes or fees “upon any business located at a commercial service airport” unless those taxes or fees are generally imposed on sales or services by the state. The district court granted summary judgment in favor of the state defendants, finding that the fee was not preempted by the AHTA.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment, but for a different reason. The Tenth Circuit held that the AHTA’s preemption provision applies only to fees or taxes imposed directly upon airport businesses, while Colorado’s congestion impact fee is imposed on consumers who rent vehicles, not on the rental businesses themselves. The court determined that rental companies and car-sharing programs merely act as collection agents for the fee, which is ultimately paid by consumers. Therefore, the federal statute does not preempt Colorado’s fee, and the district court’s judgment was affirmed. View "American Car Rental Association v. Humphreys" on Justia Law

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

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

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

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

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