On January 15, 2021, in International Brotherhood of Teamsters v. FMCSA, the 9th Circuit Court of Appeals upheld a prior decision by the Federal Motor Carrier Safety Administration (“FMCSA”) that federal law, specifically the FMCSA’s rest break regulations, preempts California’s meal and rest break rules.
Pursuant to the Motor Carrier Safety Act of 1984, if a state law is “additional to or more stringent” than federal regulations, the state law will be preempted if the FMCSA determines the state law, (1) has no safety benefit; (2) is incompatible with the federal regulation; or (3) would cause an undue burden on interstate commerce if enforced. Here, the FMSCA’s hours-of-service regulations promulgate regulations and limits on the driving time for property-carrying commercial motor vehicle drivers, whereas California’s meal and rest break rules require more frequent breaks and stringent timing regarding those breaks.
In International Brotherhood of Teamsters, supra, the Court considered Petitioner’s challenge to a prior FMCSA ruling. Specifically, the FMCSA ruled that applying the California meal and rest break rules imposes an undue burden on interstate commerce. The FMCSA reasoned that the current federal regulations address the same safety specific concerns addressed by California’s meal and rest break periods and therefore applying the state regulations would provide no “safety benefit.” The Court upheld the FMCSA’s decision concluding that California’s “additional to or more stringent” regulations would create an undue and unreasonable restraint on interstate commerce. The Court specifically noted requiring federal motor carriers to comply with the patchwork of numerous states rest and meal break regulations would be nearly impossible.
The Ninth Circuit decision minimizes the financial and administrative burden regarding federal motor carriers’ compliance with meal and rest regulations beyond those required by the Motor Carrier Safety Act. However, the decision only applies to drivers subject to the Motor Carrier Safety Act. We advise all interstate motor carriers to determine whether their drivers fall into any exceptions set forth in the Motor Carrier Safety Act before relying on the recent Ninth Circuit court’s decision.
Further, it is unclear how long the FMCSA’s ruling will stand. Nothing prevents the Teamsters from petitioning for review to the Supreme Court. Moreover, the FMCSA is an executive agency and, as noted by the Court in the Teamster’s case, has inherent authority to make new or amend prior rulings. With a new administration now in place, the FMCSA may take a more deferential position regarding states meal and rest break regulations. But for now, the decision in International Brotherhood of Teamsters is the law.
The attorneys of Poole Shaffery & Koegle, LLP remain ready and prepared to assist and advise you on all your legal needs in the transportation industry.