Appeals Court Rules on CA Meal & Rest Break Rule

In a class action suit against a large motor carrier brought by former commercial motor vehicle drivers who were paid by the hour, the 9th Circuit Court of Appeals ruled that federal regulations that preempt California’s rules on meal and rest breaks (MRB) applied retroactively to claims that existed prior to the federal rule even being implemented. 

By way of background, in December 2018, the Federal Motor Carrier Safety Administration (FMCSA) expressly preempted California’s MRB rules. The ruling by FMCSA states, “California may no longer enforce the MRB Rules with respect to drivers [who are] subject to the FMCSA’s HOS rules.” (83 Fed. Reg. 67,470) The class action that the 9th Circuit ruled on was filed in October 2018, two months before the FMCSA ruling.

The plaintiffs argued that because they had filed prior to the FMCSA decision, the preemption did not apply to them.  The 9th Circuit disagreed with the plaintiffs. Instead, the court held that “Congress intended for the FMCSA to have the power to halt enforcement of state laws” and that “the FMCSA intended for this particular preemption determination to apply to pending lawsuits.” 

While the decision was not unanimous (the judges split 2-1 in their ruling) the bottom line is that the federal government rules, like the hours of service rules, cannot be changed by an individual state. One thing to note is that this case took place in federal court, but that hasn’t stopped state courts from ruling differently. There is a case with similar facts in California state court (Garcia v Superior Court) that had a different result. The state court held that the FMCSA decision did not apply to claims filed prior to the decision. As a result, state court cases may have a different outcome than a federal court case.

You can read the federal case here.