California Court Rules No Preemption for Truck Driver Laws
A California Court of Appeals recently ruled that the Federal Aviation Administration Authorization Act (FAAAA) does not preempt California’s laws that require meal and rest breaks for truck drivers and other motor carriers. This case was brought by a class of California truck drivers claiming that
Facts of the CaseIn the case of Godfrey v. Oakland Port Services Corp., the plaintiffs were employees of AB Trucking who drove trucks for the company between the Port of Oakland and locations across the state. The drivers alleged that AB Trucking did not pay its drivers for all hours worked, misclassified some drivers as non-employee trainees and did not pay them at all, and failed to provide required meal and rest breaks. The case went to trial, and the court awarded the class of truck drivers $964,557.08 in addition to attorneys' fees, litigation expenses, and class representative enhancements. AB Trucking appealed the ruling of the trial court, and it claimed that federal law preempts the California rules that require meal and rest breaks for motor carriers. The company argued that the FAAAA preempted the state laws because it contained a section within the act that states, "a State, political subdivision of a State, or political authority of two or more States may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier . . . or any motor private carrier, broker, or freight forwarder with respect to the transportation of property."
Court RulingThe court summarily rejected all of AB Trucking's arguments regarding FAAAA preemption of California rest and meal breaks for commercial truck drivers. The court found that the company's arguments that the state laws force drivers to deviate from their routes, affect the number of deliveries a driver can make in a day, and reduce a driver's work time, thereby increasing the cost of a given set of deliveries were all without merit. Furthermore, the Court of Appeals found that the California laws regarding meal and rest breaks are not related to the "prices, routes, or services of any motor carrier" because they do not set prices, mandate or prohibit certain routes, or tell trucking companies what services they may or may not provide, either directly or indirectly. As a result, the entirety of the trial court's ruling was upheld in favor of the drivers.
Effect on EmployersAs an employer, the takeaway from this case is that California companies who employ truck drivers should adhere to California law. This includes the meal and rest breaks that are mandated by state law, even if there is a potential argument for federal preemption.