American Trucking Assns., Inc. v. Los Angeles
133 S. Ct. 2096
SCOTUS2013Background
- Port of Los Angeles governs drayage operations via a concession agreement with trucking companies; placard and off-street parking-plan requirements are challenged as preempted by federal law.
- Trucking companies are federally licensed motor carriers; port amended its tariff to condition access on concession agreement compliance.
- Concession agreement penalties include Minor and Major Default remedies, including potential suspension or revocation of port access.
- ATA sought injunction against five contract provisions, arguing § 14501(c)(1) preempts placard and parking requirements.
- District court rejected preemption arguments; Ninth Circuit affirmed in part, holding placard/parking preempted but leaving penalty-clause issue undecided on pre-enforcement posture.
- Court granted certiorari to address FAAAA preemption and Castle v. Hayes Freight Lines implications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether placard and parking provisions are preempted by § 14501(c)(1) | ATA argues these provisions have force and effect of law. | Port contends they are private-contract terms advancing proprietary interests. | Preempted; placard and parking provisions have force and effect of law. |
| Whether Castle bars enforcement of the penalty provision | Castle prohibits sanctioning federally licensed carriers for past violations via access denial. | Port argues penalty scheme could be constitutional; Castle not controlling in pre-enforcement posture. | Not decided; remanded for potential future consideration consistent with Castle. |
| Whether the enforcement scheme could apply penalties other than on the challenged provisions | ATA fears broad suspension/removal beyond preempted provisions. | Port claims only potential future use; no past application of penalties. | Not decided; limited remand pending Castle implications. |
Key Cases Cited
- American Airlines, Inc. v. Wolens, 513 U.S. 219 (1995) (distinguishes regulatory action from private contractual commitments under 'force and effect of law')
- Castle v. Hayes Freight Lines, Inc., 348 U.S. 61 (1954) (limits state enforcement of federal carrier licenses via suspension/removal)
- Rowe v. New Hampshire Motor Transp. Assn., 552 U.S. 364 (2008) (preemption applies when state actions affect the motor-carrier market through indirect means)
- Engine Mfrs. Assn. v. South Coast Air Quality Mgmt. Dist., 541 U.S. 246 (2004) (preemption when state requirements substantially regulate emissions/market)
- United Haulers Assn., Inc. v. Oneida-Herkimer Solid Waste Mgmt. Auth., 550 U.S. 330 (2007) (governmental coercive authority may render private contracts 'force and effect of law')
- Gonzales v. Raich, 545 U.S. 1 (2005) (relevance of substantial effects test; dissenting view cited for standard critique)
- Lopez v. United States, 514 U.S. 549 (1995) (Commerce Clause channels/instrumentalities/substantial effects framework)