Midwest Crane & Rigging, LLC v. Kansas Corporation Com'n, 397 P.3d 1205

Midwest Crane & Rigging operated a truck with a crane permanently bolted to its chassis and carried only crane-related tools; it drove to jobs to hoist equipment.
Kansas Highway Patrol stopped the truck for no license plate; license-plate violation later dismissed because vehicle qualified as a self-propelled crane under Kansas law.
Kansas Corporation Commission (KCC) assessed a $300 penalty under the federal Unified Carrier Registration (UCR) Act, arguing the truck was a "commercial motor vehicle" because it principally transported "cargo."
Administrative hearing and subsequent judicial review centered on whether the crane and tools constituted "cargo" under 49 U.S.C. § 31101(1), thereby subjecting the truck to UCR fees.
KCC, the district court, and a Court of Appeals majority concluded the crane and tools were cargo; a Court of Appeals dissent disagreed. Kansas Supreme Court granted review.
Kansas Supreme Court held the crane and tools are not "cargo" (they are permanently affixed and integral), so the truck is not a commercial motor vehicle under § 31101(1); the fine was vacated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a truck with a crane permanently bolted to its chassis is a "commercial motor vehicle" under 49 U.S.C. § 31101(1) because it "principally" transports cargo	Crane and tools are discrete, movable goods transported by the truck to job sites and therefore constitute "cargo"; truck principally transports those goods	The crane and tools are permanently affixed and integral to the vehicle’s function, not temporary cargo; truck’s principal use is as integrated equipment, not to transport cargo	The crane and tools are not cargo (they have more than a temporary attachment and are integral), so the truck is not a commercial motor vehicle under § 31101(1)

Yellow Transp., Inc. v. Michigan, 537 U.S. 36 (2002) (history of interstate motor-carrier registration systems)
Walters v. Metro. Educ. Enterprises, Inc., 519 U.S. 202 (1997) (statutory words read in their ordinary, contemporary meaning when undefined)
Am. Home Assur. Co. v. Fore River Dock & Dredge, Inc., 321 F. Supp. 2d 209 (D. Mass. 2004) (temporary attachment to vessel is essential to qualify as "cargo")
Zeit, 39 Kan. App. 2d 364 (2008) (Kansas classification of self-propelled crane for license-plate exemption)
American Trucking Ass'ns v. City of Los Angeles, 569 U.S. 641 (2013) (context of federal preemption and cargo/transport regulation)