American Trucking Associations v. City of Los Angeles (2012)
- Docket
- 11-798
- Decided
- 2012-01-01
Summary
Question: Can a municipal government limit the activities of motor carriers when it acts as a market participant, as opposed to a market regulator? Can a municipal government bar federally licensed motor carriers from access to a port? Conclusion: No, and the Court declined to address the issue of whether a municipal government can ban federally licensed motor carriers' access to the ports. Justice Elena Kegan delivered the opinion for a unanimous Court. The Court held that the FAAA Act draws a rough line between a government's exercise of regulatory power and its own contract-based participation in a market. In this case, the government was not acting as a private participant in a contract but was wielding coercive power over private companies by threatening criminal punishment. The Court held that these actions clearly fit within the FAAA Act's prohibition on government regulating the "price, route, or service of any motor carrier." Contractual commitments resulting from the threat of criminal sanctions rather than ordinary bargaining clearly represent the government taking on a regulatory role. Justice Clarence Thomas wrote a concurring opinion in which he noted that the FAAA Act's provision giving the federal government authority over intrastate commerce raises serious Constitutional concerns because the Constitution explicitly limits Congress' regulatory power to interstate commerce. However, because neither party raised a constitutional challenge to the FAAA Act, Justice Thomas joined with the majority.