People of the State of Cal. v. Fmcsa

── People of the State of Cal. v. Fmcsa ── Court: Court of Appeals for the Ninth Circuit Date: June 04, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT PEOPLE OF THE STATE OF No. 20-70706 CALIFORNIA EX REL. XAVIER BECERRA, as Attorney General of FMCS No. the State of California; LABOR FMCSA-2019- COMMISSIONER FOR THE STATE 0048 OF CALIFORNIA, Petitioners, OPINION v. FEDERAL MOTOR CARRIER SAFETY ADMINISTRATION, Respondent. On Petition for Review of an Order of the Federal Motor Carrier Safety Administration Argued and Submitted March 12, 2026 San Francisco, California Filed June 4, 2026 Before: Consuelo M. Callahan, Holly A. Thomas, and Anthony D. Johnstone, Circuit Judges. Opinion by Judge H.A. Thomas 2 PEOPLE OF THE STATE OF CA V. FMCSA SUMMARY * Federal Motor Carrier Safety Administration / Preemption The panel denied a petition for review brought by the People of the State of California and California officials seeking review of the determination of the Federal Motor Carrier Safety Administration (“FMCSA”) that California’s meal and rest break (“MRB”) rules, as applied to drivers of passenger-carrying commercial motor vehicles, were preempted. The Motor Carrier Safety Act (“MCSA”) requires the Secretary of Transportation to review State laws and regulations on commercial motor vehicle safety, and gives the Secretary express power to preempt State law. In 2020, the FMSCA determined that California’s MRB rules, as applied in this case, were regulations “on commercial motor vehicle safety” that were “additional to or more stringent than” the federal hours-of-service (“HOS”) regulations under 49 U.S.C. 3114. The FMSCA determined that the MRB rules were preempted because they did not provide any reasonable safety benefit beyond the safety benefit already provided by the federal HOS regulations, were incompatible with federal regulations, and imposed an unreasonable burden on interstate commerce. The panel held that petitioners’ contention that California’s MRB rules were beyond the scope of the FMSCA’s preemption authority was precluded by the * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  PEOPLE OF THE STATE OF CA V. FMCSA 3 holding in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021), cert. denied, 142 S. Ct. 93 (2021) (“Teamsters”). The panel also rejected petitioners’ argument that the FMSCA may not preempt California’s mid-shift break rules for drivers of passenger-carrying commercial motor vehicles because the agency itself has not promulgated such regulations. Petitioners read Teamsters too narrowly. Finally, the panel rejected petitioners’ argument that the FMSCA acted arbitrarily and capriciously in determining that California’s MRB rules would cause an unreasonable burden on interstate commerce. The record supports the FMSCA’s conclusion that California’s MRB rules impose a significant operational burden upon operators of passenger-carrying commercial motor vehicles. This conclusion was sufficient to justify the agency’s decision to preempt California’s MRB rules. 4 PEOPLE OF THE STATE OF CA V. FMCSA COUNSEL Casey L. Raymond (argued), California Labor Commissioner, Division of Labor Standards Enforcement, Department of Industrial Relations, Los Angeles, California; Miles E. Locker, California Labor Commissioner, Department of Industrial Relations, San Francisco, California; Timothy J. Kolesnikow, Deputy Attorney General; Miranda Maison, Supervising Deputy Attorney General; Satoshi Yanai, Senior Assistant Attorney General; Xavier Becerra and Rob Bonta, California Attorneys General; Office of the California At