American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority, 123 F.4th 27

In 2016, Rhode Island enacted the RhodeWorks Act, imposing tolls on tractor-trailers using 13 bridges on the National Highway System within the state.
The statute exempts smaller vehicles, including single-unit trucks, based on studies showing tractor-trailers cause the majority of bridge damage but contribute less than 20% of maintenance revenue.
RhodeWorks includes three daily caps on tolls: once per direction at a gantry, $20 per through trip, and $40 per day.
The American Trucking Associations and various trucking companies sued, claiming the tolls violate the dormant Commerce Clause by discriminating against interstate commerce and failing the fair-approximation test.
The district court enjoined enforcement, finding both the vehicle-class exemption and toll caps unconstitutional; Rhode Island appealed.
The First Circuit reviewed whether the toll structure discriminates against interstate commerce or unduly burdens it under Commerce Clause precedents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does exempting single-unit trucks discriminate?	Exemption favors in-state/local businesses & burdens interstate commerce	Exempted class isn’t similarly situated; no substantial competition	No discrimination—no substantial competitive effect; exemption upheld
Do toll caps discriminate against interstate commerce?	Caps benefit locals who use tolled bridges frequently, disadvantaging interstate trucks	Caps are nondiscriminatory usage-based discounts	Caps are discriminatory; they disproportionately aid in-state trucks, violating the dormant Commerce Clause
Does tolling only tractor-trailers violate fair-approximation?	Targeting only large trucks isn’t fairly apportioned to actual use or damage	Large trucks cause most of the damage; allocation is reasonable	Tolling only tractor-trailers is not wholly unreasonable; fair-approximation satisfied (absent caps)
Are the toll caps severable?	Legislative compromise hinged on the caps, so statute shouldn’t survive without them	Statute’s purpose was recurring bridge revenue; caps aren’t indispensable	Caps are severable; remainder of statute can function without them

Nw. Airlines, Inc. v. County of Kent, 510 U.S. 355 (three-prong test for public facility fees and dormant Commerce Clause)
Evansville-Vanderburgh Airport Auth. Dist. v. Delta Airlines, Inc., 405 U.S. 707 (public facility user fees must be a fair approximation of use)
American Trucking Ass'ns v. Scheiner, 483 U.S. 266 (flat fees that disproportionately burden interstate carriers violate the dormant Commerce Clause)
Exxon Corp. v. Governor of Md., 437 U.S. 117 (not every incidental burden on interstate companies constitutes discrimination)
Dep't of Revenue of Ky. v. Davis, 553 U.S. 328 (discrimination under dormant Commerce Clause requires similarly situated entities)
New Energy Co. of Ind. v. Limbach, 486 U.S. 269 (economic protectionism and discriminatory effect focus)
Pike v. Bruce Church, Inc., 397 U.S. 137 (balancing test for incidental burdens on interstate commerce)