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Metropolitan Taxicab Board of Trade v. City of New York

615 F.3d 152 (2010)

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Metropolitan Taxicab Board of Trade v. City of New York

United States Court of Appeals for the Second Circuit
615 F.3d 152 (2010)

Facts

In December 2007, the City of New York (city) (defendant) issued rules requiring new taxicabs to have a gas mileage of either 25 or 30 miles per gallon, depending on the date on which they were put into service. The city repealed these rules after a district court enjoined them on grounds that, as rules relating to fuel-economy standards, they were preempted by the Energy Policy and Conservation Act of 1975 (EPCA), which established national fuel-efficiency standards, and by the Clean Air Act (CAA). The city then issued new rules that set caps on the maximum amount that taxis could be leased for per shift. The rules distinguished between types of vehicles. Lease caps for hybrid and clean-diesel taxis were raised by $3 per shift, and lease caps for taxis that were not hybrids or clean diesel were reduced by $12 per shift. The rules were designed to incentivize reduced fuel use and cleaner taxis. The Metropolitan Taxicab Board of Trade (plaintiff), which had been a plaintiff in the case involving the earlier, repealed rule, moved for a preliminary injunction against these new rules, again arguing that they were preempted by the EPCA and the CAA.

Rule of Law

Issue

Holding and Reasoning (Walker, J.)

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