Federal District Court Holds Motor Carriers Are Not Subject To California's Meal And Rest Break Laws

A federal district court in California recently issued a decision, in Dilts v. Penske Logistics, LLC, 2011 U.S. Dist. LEXIS 122421 (S.D. Cal. Oct. 19, 2011), holding that motor carriers that transport property are not subject to California's meal and rest break laws because such laws are preempted by the Federal Aviation Administration Authorization Act (FAAA Act).

Factual Background

The plaintiffs in Penske Logistics, appliance delivery drivers and installers, filed a class action against their employer for failing to provide meal and rest breaks in addition to other wage and hour claims.

The plaintiffs claimed that the defendants violated California's meal and rest break laws by maintaining a systematic policy of automatically deducting 30 minutes of work time from the employees' hours for meal breaks, irrespective of whether duty-free meal breaks were provided, failing to account for meal breaks when scheduling deliveries/installations, not permitting drivers/installers to leave their vehicles unattended, not allowing the drivers/installers to turn off their communication devices during breaks, and not requiring them to use the communication devices to notify the company of meal and rest breaks. The defendants moved for summary judgment on the basis that the plaintiffs' meal and rest break claims are preempted by the FAAA Act.

Background on the Federal Aviation Administration Authorization Act

In 1980, Congress deregulated the trucking industry by enacting the Motor Carrier Act. In 1994, it sought to preempt state trucking regulations by enacting the FAAA Act. The Act preempts a wide range of state regulation of intrastate trucking, providing that a state "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 . . . with respect to the transportation of property." 49 U.S.C. § 14501(c)(1). Congress believed it was necessary to eliminate non-uniform state regulations that had curtailed the expansion of markets and resulted in inefficiencies, increased costs, reduced competition, and inhibition of innovation and technology. Californians for Safe & Competitive Dump Truck Transp. v. Mendonca, 152 F.3d 1184, 1187 (9th Cir. 1998).

The FAAA Act borrowed language from the Airline Deregulation Act (ADA). In passing the ADA, Congress believed that deregulating the airline industry would result in lower fares and better service. To prevent states...