On October 28, 2014, a California Court of Appeal held that the Federal Aviation Administration Authorization Act of 1994 (“FAAAA”) does not preempt California’s meal and rest break requirements as applied to motor carriers. [Godfrey v. Oakland Port Services Corp. (Cal. App. Ct. Oct. 28, 2014) Case No. A139274.]
In Godfrey, the plaintiffs were truck drivers who were predominantly assigned routes between the Port of Oakland and customer sites within the San Francisco Bay Area. In September 2010, the truck drivers filed a class action complaint against their employer alleging various violations of California’s wage and hour laws. After a bench trial, the truck drivers obtained a $964,557.08 judgment on the grounds that, inter alia, their employer failed to provide meal and rest breaks. The employer appealed and primarily argued that the FAAAA preempts California’s meal and rest break requirements.
By way of background, the FAAAA preempts all state laws “related to a price, route, or service of any motor carrier.” [49 U.S.C. § 14501(c)(2)-(3).] On appeal, the employer argued that the FAAAA preempts California’s meal and rest break requirements because the state laws: 1) force drivers to deviate from their routes; 2) affect the number of deliveries a driver can make in a day; and 3) reduce a driver’s work time, thereby increasing the cost of a given set of deliveries. Nevertheless, the court of appeal rejected all three of these arguments. In short, the appellate court ruled that California meal and rest break laws are not related to prices, routes, or services because they do not set prices, mandate or prohibit certain routes, or tell motor carriers what services they may or may not provide, either directly or indirectly. Ultimately, the court of appeal affirmed the judgment in its entirety.
The practical takeaway of Godfrey is simple: California companies who employ motor carriers should continue to comply with California’s wage and hour laws.