Companies in the transportation industry with operations in California have some positive news to celebrate. On May 3, 2019, in Anthony Ayala v. U.S. Xpress Enterprises, Inc., et al., the Central District of California granted partial summary judgment and dismissed a truck driver’s meal and rest period claims, finding that they were preempted by the December 2018 ruling of the Federal Motor Carrier Safety Administration (FMCSA).
In its December ruling, the FMCSA stated that California cannot enforce its meal and rest period laws with regard to interstate motor carriers because those laws do not provide any additional safety benefits above those already provided by the meal period rules contained in the federal hours of service rules. It also found that the California meal and rest period rules unduly burden interstate commerce.In Ayala, the plaintiff, a truck driver, sought to recover for alleged failure to provide meal and rest periods, among other wage and hour claims. The defendants sought to have the district court enforce the FMCSA’s December ruling and dismiss the plaintiff’s meal and rest period claims. The district court agreed, holding that it lacked authority to enforce California’s meal and rest period laws as applied to interstate commercial vehicle drivers. In so holding the district court explained that under applicable law, judicial review of the FMCSA’s preemption determination may only be heard by a circuit court of appeal. As such, the district court entered an order dismissing the plaintiff’s meal and rest period claims.
The Ayala decision is a powerful tool for companies in the transportation industry facing California meal and rest period claims. The issue, however, will be subject to continuing litigation. As the district court noted in Ayala, the circuit court of appeal must rule on this issue. There are a number of petitions challenging the FMCSA’s December ruling pending in the Ninth Circuit. Until there is a ruling from the Ninth Circuit (and potentially the U.S. Supreme Court), companies in the transportation industry must proceed cautiously, but also have reason for hope and another tool in their box to challenge California meal and rest period claims.