American Trucking Associations Vs City of Los Angeles Case Report (Assessment)

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Facts

In this case, American Trucking Associations Inc (the petitioner) had sued the city of Los Angeles and others (respondents). The petitioner had devised a concessional agreement with an aim of governing the relationship between the city’s port and all trucking companies that were operating in the port facilities. The agreement paper required all truck owners to fix a placard on their vehicles, each of which was supposed to bear a phone number.

Issue

Sometimes later, the city of Los Angeles did some amendments to its previous tariff with an aim of forcing all truck companies were party to the agreement. This means that the city wanted all the companies seeking to use the facility were part of its agreement. The requirement further placed a criminal prohibition on the company owners who attempted to violate the regulations. The petitioner sued the respondent, citing the Federal Aviation Administration authorization act 1994 as having been violated.

Rule

The US Supreme court, sitting in Los Angeles, determined that section 49 of the USCS subsection 14501 (c) (1) expressly pre-empted the placard and provisions for parking as shown in the city’s concession agreement because the requirements therein had the necessary and reasonable effect and force of the federal law. This was determined because the agreement was functioning as a part of the authority’s program that exercised its powers over private companies. In addition, it was backed by criminal punishment. Thus, the SC reversed the judgment by the circuit court, although in part, to the agreement as well as parking provisions. In addition, the court declined to decide on the trade associations. It referred them to further hearings.

Application

The Federal Aviation Administration Authorization Act 1994 is one of the legislation under the public transport laws of the US. It prohibits local governments from developing their own regulations to control carriers that are licensed by the federal government. In this context, the law provides that may not enact its own law or enforce legislation or regulation of any kind related to issues such as pricing, service, or routing of motor carriers (The Oyez Project at IIT Chicago-Kent College of Law, 2013).

The petitioner referred to case law Castle v. Hayes Freight Lines, Inc, in which the ninth circuit court had argued that a state could not enforce its regulations on valid motor carriers through “partial suspension” of the carrier’s access to any channel serving any interstate business. However, the respondent defended itself by arguing that the concessional agreement was not affecting by the requirements of FAAAA 1994. In its response, POLA argued that its agreement was exempted as a market participant.

Conclusion

The case will be used to determine whether the regulations within FAAAA pre-empts “off-street” parking. It will also be used to determine the legal justification of any provision of placard by city and municipality concessions agreements. In addition, it will be used in the legal determination of whether the market participant doctrine applies in interstate commerce. Moreover, it will determine whether the decision by the circuit court in the Castle v. Hayes Freight Lines, Inc bars city and municipality authorities like POLA from enacting their laws and enforcing their own concession agreements through such processes as suspending or revoking access to the facilities. The decision by the Supreme Court of the US will be used to describe the line separating the powers of local authorities and national government in the transportation sector.

Reference

The Oyez Project at IIT Chicago-Kent College of Law. (2013). American Trucking Associations v. the City of Los Angeles. Web.

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