Chambers v. RDI Logistics, Inc., 476 Mass. 95

Background

Plaintiffs Chambers and Johnson (who formed small companies to contract with RDI) worked full time as furniture delivery drivers for RDI and allege long‑term control by RDI (uniforms, logos on trucks, routed GPS, scheduled delivery windows, deductions, noncompete/nonsolicit clauses).
Plaintiffs filed a putative class action under Mass. Gen. Laws ch. 149, § 148B (the independent contractor statute), alleging misclassification; Chambers also alleged individual retaliation under G. L. c. 149, § 148A after he was fired.
During discovery RDI mailed certain current/former drivers $1,000 checks with releases; plaintiffs sought an emergency protective order to enjoin such communications and void releases, which the trial judge denied.
The trial judge granted defendants’ cross‑motion for summary judgment, dismissing plaintiffs’ misclassification claim on grounds that the Federal Aviation Administration Authorization Act (FAAAA), 49 U.S.C. § 14501(c), preempted the state statute in its entirety; the judge also dismissed related claims and counterclaims as moot.
The SJC granted direct review and vacated the summary judgment, holding that only prong two of § 148B is preempted by the FAAAA, that prong is severable, and that material factual disputes remain on misclassification, standing, and Chambers’s retaliation claim; the denials of the protective order motions were affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether G. L. c. 149, § 148B is preempted by the FAAAA as applied to motor carriers	§ 148B is a valid state worker‑classification statute and not preempted; it protects workers	FAAAA preempts any state law that "relates to" motor carriers’ prices, routes, or services; § 148B (especially prong two) impermissibly dictates how carriers provide services	Prong two (the "outside the usual course of business" prong) is preempted because it effectively bars motor carriers from using independent contractors for delivery services; the rest of § 148B is not preempted as applied to motor carriers.
Severability of prong two from § 148B	Entire statute should remain; Legislature intended conjunctive three‑prong test	Prongs are conjunctive and inseparable; if prong two invalid, whole statute should fall	Prong two is severable under Massachusetts law; first and third prongs can stand and further the Legislature's protective purpose.
Whether enforcing the severed statute (prongs one and three) is preempted because it affects carriers’ services	Enforcement is a generally applicable labor regulation several steps removed from rates/routes/services	Any state regulation that affects carriers’ costs or operations is preempted	Enforcement of prongs one and three does not have the requisite "significant impact" on services/rates/routes and is not preempted.
Whether plaintiffs (who contracted through corporations) have standing under § 148B	Plaintiffs allege they incorporated only to contract with RDI and were forbidden to work elsewhere; they should be able to assert statutory protections	Plaintiffs voluntarily used corporate form and thereby lack "individual" status under the statute	Material facts are disputed about whether incorporation was a sham or employer‑imposed; summary judgment on standing was improper.
Denial of emergency protective order after RDI mailed settlement checks/releases	RDI’s letters were coercive/misleading to putative class members and required an order barring contacts and voiding releases	Letters fairly notified recipients, invited counsel consultation, and were not coercive; protective orders implicate First Amendment limits	Trial judge did not abuse discretion in denying the protective order on the record; courts retain authority to enter protective orders if coercion/misleading conduct is shown.

Key Cases Cited

Somers v. Converged Access, Inc., 454 Mass. 582 (summarizing independent contractor statute and summary judgment standard)
Depianti v. Jan‑Pro Franchising Int'l, Inc., 465 Mass. 607 (explaining purpose and burden under § 148B)
Sebago v. Boston Cab Dispatch, Inc., 471 Mass. 321 (noting presumptive employee status under statute)
Rowe v. New Hampshire Motor Transp. Ass'n, 552 U.S. 364 (FAAAA preemption framework; "significant impact" test)
Gulf Oil Co. v. Bernard, 452 U.S. 89 (court's authority and limits to regulate communications in class actions)