Justia Transportation Law Opinion Summaries

The case involves José Ramón López Regueiro, who filed a lawsuit against American Airlines, Inc. under Title III of the Helms-Burton Act. Regueiro alleged that his father purchased Cuba’s main airport, which was later confiscated by Fidel Castro’s regime. Regueiro inherited his father’s interest in the airport and became a U.S. citizen in 2015. He claimed that American Airlines trafficked in the confiscated property by operating flights in and out of the airport.The United States District Court for the Southern District of Florida dismissed the case. The court agreed with American Airlines that the Helms-Burton Act implicitly required the property owner to be a U.S. citizen when the property was confiscated and the plaintiff to be a U.S. citizen when they acquired an interest in the property. Since Regueiro’s father was not a U.S. citizen when the airport was confiscated and Regueiro became a U.S. citizen only after inheriting the property, the court ruled that Regueiro failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s interpretation. The appellate court concluded that the Helms-Burton Act does not impose the preconditions that American Airlines argued. The Act provides a cause of action to any U.S. national who owns a claim to confiscated property, regardless of the owner’s citizenship status at the time of confiscation or acquisition. The court also rejected American Airlines’s argument that Regueiro’s ownership of shares in the company that owned the airport did not constitute an ownership interest in the airport itself. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Regueiro v. American Airlines, Inc." on Justia Law

Michael Muir, who has a congenital birth defect presenting as a hernia in his right scrotum, challenged the Transportation Security Administration’s (TSA) Final Rule authorizing the use of Advanced Imaging Technology (AIT) scanners at airport security checkpoints. Muir argued that the scanners, which use electromagnetic radiation, flag his hernia as a threat, leading to painful and potentially life-threatening pat-downs. He claimed that the Final Rule and TSA’s standard operating procedures (SOPs) are arbitrary and capricious, contrary to TSA’s statutory authority, and violate Section 504 of the Rehabilitation Act of 1973.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The court found that Muir had not raised his statutory challenges during the rulemaking process, resulting in forfeiture of those claims. However, the court agreed with Muir’s Rehabilitation Act claim, noting that TSA’s failure to provide an accommodation for his disability could be a violation of the Act. The court determined that Muir had identified a reasonable accommodation—screening with a walk-through metal detector (WTMD)—and remanded the case to TSA to determine if this accommodation would impose an undue burden on the agency.The court denied Muir’s other challenges to the Final Rule and his motion to supplement the record. The court emphasized that TSA must conduct the appropriate administrative process to address the implementation of Muir’s reasonable accommodation and explore alternative accommodations if necessary. View "Muir v. Department of Homeland Security" on Justia Law

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt.The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law

Crowley Government Services, Inc. ("Crowley") entered into a contract with the Department of Defense United States Transportation Command ("USTRANSCOM") in 2016 to provide transportation coordination services, which involved hiring motor carriers to transport freight. The General Services Administration ("GSA"), not a party to the contract, began auditing Crowley's bills under a provision of the Transportation Act of 1940, claiming Crowley overbilled USTRANSCOM by millions of dollars. GSA sought to recover these overcharges by garnishing future payments to Crowley.The United States District Court for the District of Columbia dismissed Crowley's Administrative Procedure Act ("APA") claims, holding that the claims were essentially contractual and fell within the exclusive jurisdiction of the Court of Federal Claims. The D.C. Circuit reversed, finding that Crowley's suit was not a contract claim and remanded the case. On remand, the District Court held that GSA could audit both carriers and non-carriers but agreed with Crowley that the USTRANSCOM Contracting Officer's interpretations governed any GSA audits. The court enjoined GSA from issuing Notices of Overcharge ("NOCs") contrary to the Contracting Officer's determinations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that 31 U.S.C. § 3726(b) allows GSA to audit only bills presented by carriers and freight forwarders. The court found that Crowley is not a carrier because it does not physically transport freight nor is it contractually bound to help perform the movement of goods. Consequently, the court reversed the District Court's decision on the scope of § 3726(b) and remanded for further proceedings, permanently enjoining GSA from conducting postpayment audits of Crowley's bills. View "Crowley Government Services, Inc. v. General Services Administration" on Justia Law

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Robert Cox, acting as the personal representative and special administrator of the estate of Greta Cox, sued Total Quality Logistics, Inc. and Total Quality Logistics, LLC (collectively, TQL) for negligence under Ohio law. Cox alleged that TQL, in its role as a freight broker, negligently hired an unsafe motor carrier, Golden Transit, Inc., which resulted in a motor vehicle crash that killed his wife, Greta Cox. The crash occurred when the driver of the motor carrier, Amarjit Singh Khaira, failed to slow down in a construction zone and collided with Greta Cox's vehicle.The United States District Court for the Southern District of Ohio dismissed the case, ruling that Cox’s claims were preempted by the Federal Aviation Administration Authorization Act (FAAAA), specifically 49 U.S.C. § 14501(c). The district court found that the FAAAA preempted the state law claims because they related to the services of a broker with respect to the transportation of property and did not fall within the Act’s safety exception.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred in its interpretation of the FAAAA’s safety exception. The Sixth Circuit concluded that the safety exception, which preserves the safety regulatory authority of a state with respect to motor vehicles, includes common law claims like Cox’s negligent hiring claim. The court reasoned that such claims are genuinely responsive to safety concerns and directly involve motor vehicles and motor vehicle safety. Therefore, the court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cox v. Total Quality Logistics, Inc." on Justia Law

Several rail carriers challenged a Final Rule issued by the Surface Transportation Board (STB) that allows a railway shipper or receiver to request a "reciprocal switching agreement." This agreement requires a rail carrier with a monopoly over a certain rail line to compete with another carrier for specific rail traffic. The carriers argued that the Final Rule exceeded the STB's statutory authority under the Staggers Rail Act of 1980, which grants the agency authority to prescribe reciprocal switching. They also contended that aspects of the Final Rule exceeded the Board's ancillary powers and were arbitrary, capricious, and unsupported by the record.The STB issued the Final Rule after a notice-and-comment period, aiming to address service performance issues of Class I rail carriers, which were exacerbated by the COVID-19 pandemic. The Board held a hearing in April 2022 and required several Class I carriers to submit service recovery plans. Subsequently, the Board proposed new regulations to improve service by increasing competition, leading to the Final Rule. The rule establishes procedures for shippers or receivers to request reciprocal switching agreements if the incumbent carrier fails to meet certain performance standards.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the Final Rule exceeded the STB's statutory authority because it did not require a finding of inadequate service by the incumbent carrier before prescribing a reciprocal switching agreement. The court emphasized that the Staggers Rail Act requires such a finding to determine that a reciprocal switching agreement is "in the public interest." Consequently, the court granted the petition, vacated the Final Rule, and remanded the case to the STB for further proceedings. View "Grand Trunk Corporation v STB" on Justia Law

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo.The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment.The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

In 2016, Tucker Cianchette secured a multimillion-dollar judgment in Maine Superior Court against his father, step-mother, and two LLCs after they backed out of a 2015 agreement that would have given him sole control of a Ford dealership. Following this, in 2021, Eric and Peggy Cianchette, along with Cianchette Family, LLC, and Better Way Ford, LLC, filed a lawsuit alleging that Ford Motor Company violated state and federal laws during the failed 2015 negotiations and through false testimony by Ford employees in Tucker's 2016 suit.The 2021 lawsuit was initially filed in Maine Superior Court but was removed to the United States District Court for the District of Maine. The District Court dismissed all claims against Ford, leading the plaintiffs to appeal. The plaintiffs argued that Ford's actions during the 2015 negotiations and the 2016 lawsuit constituted violations of Maine's civil perjury statute, the Dealers Act, the federal Automobile Dealers' Day in Court Act, and also amounted to breach of contract and tortious interference with contract.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The Court of Appeals held that the plaintiffs failed to plausibly allege that Ford made any false representations or that any reliance on such representations was justified. The court also found that the plaintiffs' claims under the Dealers Act were barred by res judicata due to a prior ruling by the Maine Motor Vehicle Franchise Board. Additionally, the court concluded that the implied covenant of good faith and fair dealing did not apply to the breach of contract claims under Michigan law, as the SSA explicitly granted Ford the right to approve changes in ownership. View "Better Way Ford, LLC v. Ford Motor Company" on Justia Law

Michael Solondz, a commercial airline pilot, was diagnosed with anxiety and prescribed mirtazapine after experiencing side effects from another medication. Mirtazapine effectively managed his anxiety without significant side effects. Solondz sought medical clearance from the Federal Aviation Administration (FAA) to resume flying, but the FAA categorically disallows pilots from flying while taking mirtazapine, despite allowing conditional approvals for other antidepressants.The FAA denied Solondz's request for a Special Issuance medical certificate multiple times, citing his use of mirtazapine, anxiety, sleep apnea, optic neuritis, and a history of atrial fibrillation. Solondz provided evidence that his conditions were well-managed and that mirtazapine did not cause significant side effects. The FAA's final denial letter reiterated these reasons and added a concern about a potential malignant melanoma diagnosis, which Solondz disputed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the FAA failed to provide a reasonable explanation for categorically disallowing pilots taking mirtazapine from obtaining medical certification. The court noted that the FAA's process for conditionally approving other antidepressants involves a six-month waiting period and individualized medical assessments, which could also apply to mirtazapine.The court vacated the FAA's final denial letter and remanded the case for further explanation. The court emphasized that the FAA must articulate a clear rationale for its policy and avoid offering explanations that contradict the evidence. The petition for review was granted, and the case was remanded to the FAA for further proceedings consistent with the court's opinion. View "Solondz v. FAA" on Justia Law