Massachusetts Delivery Assoc. v. Coakley
769 F.3d 11
| 1st Cir. | 2014Background
- MDA challenges Massachusetts Gen. Laws ch. 149, § 148B(a)(2) (B Prong) as preempted by the FAAAA’s express preemption of state laws related to price, route, or service of motor carriers with respect to the transportation of property.
- Xpressman Trucking & Courier relied on independent contractors to perform most couriers’ deliveries; it argues B Prong forces misclassification of couriers as employees under state law.
- MDA seeks declaratory judgment that §148B(a)(2) is preempted and injunctive relief against enforcement by the Attorney General.
- District court held §148B is not preempted and denied preemption on the merits; it reserved Rule 56(d) issues for further discovery.
- This appeal focuses on whether the FAAAA preempts §148B(a)(2) under the broad “related to a price, route, or service” standard and under the “with respect to the transportation of property” clause, and on the proper scope of preemption.
- Court reviews preemption de novo and remands for a full record on the first-prong analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does FAAAA preempt §148B(a)(2) (B Prong)? | MDA argues B Prong bans misclassification as independent contractors. | GOVERNMENT contends B Prong can be preempted when structure affects prices/routes/services. | Yes; preemption proper under broad ‘related to’ test. |
| What is the proper scope of ‘related to a price, route, or service’ under FAAAA? | Preemption should extend to statutes with significant connection to prices/services. | Statutes with only tenuous, general impact are not preempted. | Expansive but not unlimited; analysis beyond surface labels required. |
| Does the clause ‘with respect to the transportation of property’ narrow preemption to only laws directly regulating transport of property? | §148B affects delivery services, routes, and pricing of property transport. | Dan's City narrows scope; some impact outside transport may be non-preemptive. | Dan's City limits but does not eliminate preemption where law affects transport. |
Key Cases Cited
- Dan's City Used Cars, Inc. v. Pelkey, 133 S. Ct. 1769 (2013) (interprets ‘with respect to the transportation of property’ to require connection to the transportation of property; limits preemption scope)
- Rowe v. N.H. Motor Transp. Ass'n, 552 U.S. 364 (2008) (broadly defines ‘related to’ as connection to prices, routes, or services; admissible preemption)
- Morales v. Trans World Airlines, Inc., 504 U.S. 374 (1992) (establishes expansive meaning of ‘related to’ in ADA/FAAAA context)
- Northwest, Inc. v. Ginsberg, 134 S. Ct. 1422 (2014) (breach-of-implied-contract claim ‘relates to’ airline prices/services; supports broad preemption view)
- DiFiore v. Am. Airlines, Inc., 646 F.3d 81 (2011) (preemption review is statutory-interpretation focused; not all general laws are exempt)