Supreme Court rules federal law does not bar state claims over vehicle towing

[JURIST] The US Supreme Court [official website] ruled unanimously [opinion, PDF] in Dan's City Used Cars, Inc. v. Pelkey [SCOTUSblog backgrounder; JURIST report] that section 14501(c)(1) of the Federal Aviation Administration Authorization Act (FAAAA) [text] does not preempt state-law claims stemming from the storage and disposal of a towed vehicle. Section 14501(c)(1) reads: "a State ... may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier ... with respect to the transportation of property." In an opinion authored by Justice Ruth Bader Ginsburg, the court held:

that state-law claims stemming from the storage and disposal of a car, once towing has ended, are not sufficiently connected to a motor carrier's service with respect to the transportation of property to warrant preemption under §14501(c)(1). The New Hampshire law in point regulates no towing services, no carriage of property. Instead, it trains on custodians of stored vehicles seeking to sell them. Congress did not displace the State's regulation of that activity by any federal prescription.
The court affirmed the decision [text] of the New Hampshire Supreme Court.

Dan's City Used Cars towed Robert Pelkey's car while he was in the hospital for two months and eventually traded the car away without compensating Pelkey. Pelkey brought suit under New Hampshire law. The district court granted summary judgment for Dan's City, finding that Pelkey's claims were preempted by federal law.

 

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