Owner-Operator Independent Drivers Ass'n v. Supervalu, Inc., 2011 U.S. App. LEXIS 16510

OOIDA, Rajkovacz, and Schaefer, LLC sue Supervalu under 49 U.S.C. §14103(a) for reimbursement of lumping fees at Supervalu facilities.
Supervalu contracted lumping services and imposed higher insurance requirements on self-loading/unloading drivers in 2005, later reduced to federal minimums.
District court granted summary judgment for Supervalu, holding OOIDA must prove non-reimbursement by shipper and that the insurance rule was unreasonable, and held §14704(a)(1) provides only injunctive relief.
OOIDA argued the statute imposes a broad duty to compensate when lumping is required, not contingent on shipper reimbursement; sought restitution and accounting.
The Eighth Circuit affirmed, concluding the district court correctly ruled OOIDA failed to show unreimbursed lumping costs; the statutory language is ambiguous but the court’s interpretation is consistent with intent, and restitution is not available in private §14103 actions.
Concurring opinion agrees with dismissal of restitution and emphasizes that monetary relief is not authorized in private actions under §14704(a)(1).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is §14103(a) satisfied only if the trucker shows unreimbursed lumping costs?	OOIDA asserts the shipper/receiver reimbursement requirement is not tied to who required lumping.	Supervalu argues reimbursement can come from either shipper or receiver; the statute does not tie liability to the same party who required lumping.	Ambiguous; plaintiff must show unreimbursed costs by a shipper or receiver
Does Super valu's insurance requirement render a de facto lumping obligation unreasonably burdensome?	OOIDA contends the insurance requirement effectively forces hiring Supervalu lumpers at drivers' cost.	Supervalu contends the requirement is reasonable if tied to statutory minimums; no explicit coercion shown.	Not reached on final merits; issue reserved after ambiguity resolution; district court's outcome preserved
Whether private §14704(a)(1) allows restitution or only injunctive relief for §14103 violations against a shipper/receiver	OOIDA seeks monetary relief (restitution/accounting) under private action.	Supervalu argues §14704(a)(1) only allows injunctive relief in private actions and does not authorize restitution.	Monetary relief not available in private action under §14704(a)(1) for §14103 violations

United States v. I.L., 614 F.3d 817 (8th Cir.2010) (statutory-interpretation baseline; plain-language approach)
Estate of Farnam v. Comm'n of Internal Revenue, 583 F.3d 581 (8th Cir.2009) (interpretation requires reading statute as a whole; ambiguity permitting history use)
Jessep v. Jacobson Transp. Co., Inc., 350 F.3d 739 (8th Cir.2003) (context on MCA lumping provisions and private contracting framework)
Meghrig v. KFC W., Inc., 516 U.S. 479 (1996) (limits private monetary relief when explicit remedies exist)
Porter v. Warner Holding Co., 328 U.S. 395 (1936) (private-equity relief boundaries; restitution not implied when statute specifies injunctive relief)
Mitchell v. Robert De Mario Jewelry, Inc., 361 U.S. 288 (1960) (restitution not assumed absent explicit statutory authorization in public actions)
Mertens v. Hewitt Assocs., 508 U.S. 248 (1993) (equitable relief scope in private actions governed by specific statutory scheme)
United Van Lines, LLC v. Jessep, 556 F.3d 690 (8th Cir.2009) (statutory interpretation and legislative-history approach in MCA-II context)