The Federal Court of Appeals for the Fourth Circuit recently sided with the Federal Motor Carrier Safety Administration in a case involving a stop work order. As many in the trucking industry know, the FMCSA wields great power in how they regulate trucking and transportation companies. A stop work order for any reason can devastate a company’s current and future business prospects.
That is what happened in this case. In Haines v. FMCSA, No. 15-1624 (4th Cir. 2016), a transportation company broke some agency regulations, and once the agency got wind of it, they shut down not only the vehicle breaking the regulation, but the entire fleet. The agency did it by issuing a stop work order.
Ultimately, this stop work order devastated this particular transportation company. It was months before the owner could get his business started again, and in the meantime, he lost a lot of value in reputation, revenue, and future prospects.
Company Sues for Damages Done
In the wake of all this commotion, the company owner decided to sue the FMCSA. Their suit was based on several claims, including that the agency violated:
- The Administrative Procedures Act by acting capriciously; and
- The company’s due process and equal protection under the Fourteenth Amendment.
At the federal district court level, the case did not make it far. The federal judge ruled on the motions and granted the FMCSA’s motion to dismiss for failure to state a claim.
The problem with this case, and related cases, is the uphill battle that any litigant faces when taking on a federal agency. The laws and regulations involved are much more complex than other, typical transportation litigation, and can easily be lost procedurally if not pleaded properly. But even when cases are pleaded properly, due to the nature of the work of an agency, it can be difficult to prevail because the weight of the federal government is behind an agency.
Following the district court ruling, the owner appealed to the Fourth Circuit Court of Appeals. The appeal was not effective either. In their opinion the court discussed the reasons why the claims failed, including that the courts did not have jurisdiction to hear the case. Many times before a company can sue an agency in federal court, the company must exhaust all of the appeals possible within the agency, and then proceed to federal court.
In this case, failure to exhaust all of the company’s remedies with the agencies was just one of the problems with the complaint. But the overall case is illustrative of how complex and involved transportation law can be. It involves not only federal statutes and court opinions, but also federal regulations, state law, and state regulations. That is why choosing the right legal partner is key for any company in the transportation industry.
At Anderson and Yamada, P.C., our transportation law practice has years of experience your company can count on. As your company navigates its way into the future, contact us to help you manage all of the legal challenges you will face.