Checker Cab Operators, Inc. v. Miami-Dade County.
899 F.3d 908
11th Cir.2018Background
- Miami‑Dade County historically regulated for‑hire transportation via a medallion system (created by a 1998 ordinance) that made medallions an "intangible property" license to provide taxi service and limited alienability and operation.
- From 1998–2016 the County amended rules and issued additional medallions but retained regulatory control (vehicle standards, fares, inspections, background checks, suspension/revocation).
- In May 2016 the County enacted a TNE Ordinance authorizing Transportation Network Entities (TNEs, e.g., Uber/Lyft) to operate without medallions and established a distinct regulatory regime; medallion values dropped substantially.
- Plaintiffs (medallion holders) sued claiming: (1) the TNE Ordinance effected a Fifth Amendment/Florida takings by eliminating their market exclusivity and devaluing medallions; and (2) the ordinance violated equal protection by subjecting medallion holders to more stringent rules than TNEs.
- The district court dismissed for failure to state a claim; after that dismissal Florida enacted a preemptive state TNE law, mooting claims for declaratory/injunctive relief but not monetary damages, prompting this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Takings: whether medallions included a right to exclude competitors (market exclusivity) | Medallions were "intangible property" that entitled holders to an exclusive right to provide for‑hire service; permitting TNEs took that right without compensation | Medallions are licenses to operate subject to extensive regulation; County never conveyed a right to exclude competitors or a perpetual monopoly | Dismissed — no constitutionally protected property right to exclude competitors; diminution from competition is not a compensable taking |
| Mootness of prospective relief | Plaintiffs sought declaratory/injunctive relief against the TNE Ordinance | County argued state preemption mooted prospective claims | Vacated/dismissed as moot — Florida’s later preemptive statute eliminated the TNE Ordinance so prospective relief is unavailable; monetary claims remain live |
| Equal Protection: disparate regulations for taxicabs vs. TNEs | Different rules (chauffeur agreements, insurance, inspections, appearance, fares) irrationally disadvantaged medallion holders | Differences reflect distinct business models and are rationally related to legitimate governmental interests (safety, consumer protection, appearance, fare transparency) | Dismissed — rational‑basis review satisfied; regulatory differences are rationally related to legitimate objectives |
| Leave to amend | Plaintiffs sought leave to amend to cure defects | County argued amendment would be futile | Denied — proposed amendment would restate same arguments and remain futile |
Key Cases Cited
- Ill. Transp. Trade Ass'n v. City of Chicago, 839 F.3d 594 (7th Cir. 2016) (taxi medallions do not include a right to be free from competition)
- Joe Sanfelippo Cabs, Inc. v. City of Milwaukee, 839 F.3d 613 (7th Cir. 2016) (taxi permits are property but do not confer control over all transportation competitors)
- Minneapolis Taxi Owners Coal., Inc. v. Minneapolis, 572 F.3d 502 (8th Cir. 2009) (license takings claim cannot assert a broader property interest than the one actually possessed)
- Ruckelshaus v. Monsanto Co., 467 U.S. 986 (1984) (property interests are defined by existing rules/understandings from state law)
- Bd. of Regents v. Roth, 408 U.S. 564 (1972) (property interests arise from state law and legitimate claims of entitlement)
- Penn Central Transp. Co. v. New York City, 438 U.S. 104 (1978) (factors for regulatory takings analysis)
- Lucas v. S.C. Coastal Council, 505 U.S. 1003 (1992) (expectations of property owners limited where regulation could render property economically worthless)