Background
In 2020, the Federal Motor Carrier Safety Administration determined that California’s meal and rest break rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted. The agency found the rules were additional to or more stringent than federal hours-of-service regulations, provided no measurable safety benefit, were incompatible with federal rules, and imposed an unreasonable burden on interstate commerce. California officials petitioned the Ninth Circuit for review of this preemption determination.
The court’s reasoning
The panel held that the petitioners’ contention that the rules were beyond the scope of the agency’s preemption authority was precluded by the court’s prior decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration. The court rejected the argument that the agency could not preempt mid-shift break rules because it had not promulgated such regulations, noting that federal hours-of-service regulations still govern the same subject area of fatigue management. Finally, the panel found the record supported the agency’s conclusion that the state rules imposed a significant operational burden on operators and created a patchwork of requirements that burdened interstate commerce.
What it means going forward
California’s meal and rest break rules remain preempted as applied to drivers of passenger-carrying commercial motor vehicles subject to federal hours-of-service regulations, maintaining the federal regulatory framework for driver duty and driving times.