Koch Foods, Inc. v. Secretary, U.S. Dept. of Labor for Occupational Safety and Health, 712 F.3d 476

Bailey, a Koch Foods driver, became overweight trailers were used after Koch Foods acquired his plant.
Bailey refused to drive an overweight trailer, was suspended, then fired for refusing a reasonable assignment.
Bailey filed an OSHA complaint alleging STAA retaliation for his refusal to drive overweight vehicle.
ALJ found Bailey’s belief the vehicle was overweight was objectively reasonable, protected activity.
ARB affirmed, adopting a subjective belief element and holding protection extended to reasonable belief of violation.
Court vacates ARB and remands to determine whether Bailey’s assigned vehicle would have actually violated a safety regulation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §31105(a)(1)(B)(i) requires an actual violation	Koch Foods: protection only if actual violation	Secretary: statute ambiguous; ARB reasonable belief is protected	Unambiguous; requires actual violation; remand to assess actual violation
Chevron deference and statutory interpretation	Koch Foods: ARB interpretation improper	Secretary: ARB interpretation reasonable under Chevron	No deference; statute clear; ARB interpretation rejected

Brock v. Roadway Express, 481 U.S. 252 (1987) (STAA protection for refusals to drive in safety violations context)
Yellow Freight Sys., Inc. v. Reich, 38 F.3d 76 (2d Cir. 1994) (protective scope for refusals where related to safety conditions)
Griffith v. United States (In re Griffith), 206 F.3d 1389 (11th Cir. 2000) (treats silence as not implying change in law; interpret statutes by text)
Finley v. United States, 490 U.S. 545 (1989) (restructuring codifications do not imply substantive change without clear expression)
Edison v. Douberly, 604 F.3d 1307 (11th Cir. 2010) (statutory-context-based interpretation; avoid isolated word focus)
Josendis v. Wall to Wall Residence Repairs, Inc., 662 F.3d 1292 (11th Cir. 2011) (statutory interpretation; context matters)