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Massachusetts Delivery Ass’n v. Coakley

The Massachusetts Delivery Association brought this case against the Massachusetts Attorney General, contending that the Federal Aviation Administration Authorization Act of 1994 (FAAAA), which prohibits states from enacting or enforcing laws “related to a price, route, or service of any motor carrier . . . with respect to the transportation of property” preempts a Massachusetts statute requiring workers to be classified as employees rather than independent contractors for the purpose of the state’s wage laws if the workers perform services within the usual course of the employer’s business. The district court held that the provision is not preempted. On appeal to the First Circuit, Public Citizen filed an amicus brief in support of the Massachusetts Attorney General explaining that the FAAAA does not preempt laws that do not target motor carriers “with respect to the transportation of property,” and that background employment laws do not “relate to” motor carrier prices, routes, or services. The First Circuit reversed the district court’s decision and remanded to the district court to determine, based on a full review of the record, whether the law’s effect on prices, routes, and services is sufficiently significant for it to be preempted.