13 June 2013

Law in Plain English: American Trucking Associations, Inc. v. City of Los Angeles

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

American Trucking Associations, Inc. v. City of Los Angeles

In order to expand the Port of Los Angeles, the Port adopted an environmental plan that required licensed motor carriers (LMC) to make certain concessions. The American Trucking Associations (ATA) challenged several requirements as preempted by the Federal Aviation Administration Authorization Act (FAAAA). The Port argued that they were a market participant which effectively gives them an exception to preemption (and thus allowing the plan's challenged provisions to go forward), although (as ATA argued) the text of the FAAAA contains no such provision. Nonetheless, the District Court agreed with the Port and the Ninth Circuit affirmed. The question before the Court was Whether the FAAAA contains an unexpressed “market participant” exception and permits a municipal governmental entity to take action that conflicts with the express preemption clause, occurs in a market in which the municipal entity does not participate, and is unconnected with any interest in the efficient procurement of services. In a unanimous decision, the Supreme Court ruled that the FAAAA expressly preempts the challenged requirements. As a result, the ATA's motor carriers won't be required to make the concessions demanded by the port.
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