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U.S. Ninth Circuit Upholds Federal Hours-of-Service Requirements for Commercial Vehicle Drivers

In its recent International Brotherhood of Teamsters v. FMCSA decision, the U.S. Ninth Circuit Court of Appeals upheld the Federal Motor Carrier Safety Administration’s (“FMCSA”) determination that federal law preempts California’s meal and rest break (“MRB”) rules as applied to property-carrying commercial motor vehicle drivers who are subject to the FMCSA’s hours-of-service requirements.

In 2011, the FMCSA revised its federal regulations to require that commercial motor vehicle drivers must take one 30-minute break during the first eight hours of work while allowing the driver to decide when to take the break.  California’s MRB rules mandate stricter requirements, including when the breaks can be taken and restricting meal periods and rest breaks from being combined into one longer break.  In 2018, the FMCSA declared that California’s MRB rules were preempted by federal law as they applied to commercial drivers subject to federal hours-of-service requirements.

In its International Brotherhood of Teamsters ruling, the Court held that the FMCSA acted within its authority when it determined that California’s MRB rules were attempting to regulate “commercial motor vehicle safety” and were preempted by federal law.  The Court upheld the FMCSA’s decision that California’s MRB rules “more stringent” than federal requirements and placed an “unreasonable burden on interstate commerce.”  The Court further ruled that the FMCSA’s federal regulations adequately balanced the competing interests between safety and economic burden.

This new ruling is a win for companies that employ property-carrying commercial motor vehicle drivers who are subject to federal regulations, as it limits the application of California’s MRB rules.  For more information about how this ruling may impact your business, contact the transportation attorneys at Chauvel & Glatt.


The material in this article, provided by Chauvel & Glatt, is designed to provide the informative and current information as of the date of the post. It should not be considered, nor is it intended to constitute, legal advice or promise similar outcomes.  For information on your particular circumstances, please contact Chauvel & Glatt at 650-573-9500. (photo credit: 123rf.com)


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