United States v. American Trucking Associations, Inc.

In 1935 the Motor Carrier Act was passed to regulate the motor-carrier industry. Section 204(a) of the Motor Carrier Act tasked the Interstate Commerce Commission (the commission) (defendant) with establishing reasonable requirements in several areas of the motor-carrier industry, including in relation to the maximum hours of service for employees and the safety of operation and equipment. Section 204(a)(3) specifically allowed the commission to establish the maximum hours of service for employees as necessary to promote the safety of operation. The commission had recommended the provision to Congress. Soon after the Motor Carrier Act passed, the commission set maximum hours of service for employees whose work in the motor-carrier industry implicated safety concerns. After the commission made its maximum-hour regulations, the Fair Labor Standards Act was enacted to establish maximum hours for certain workers. Employees who worked in the motor-carrier industry and who were subject to the commission’s regulations were exempt from the Fair Labor Standards Act. In Ex Parte No. MC-28, the commission concluded that nontransportation workers within the motor-carrier industry were subject to the Fair Labor Standards Act rather than the Motor Carrier Act. The commission reasoned that Congress only intended for the commission’s power under the Motor Carrier Act to apply to employees whose work affected the safety of operation. The American Trucking Associations, Inc. (the association) (plaintiff) petitioned the commission to reconsider its rule that nontransportation workers did not fall under the commission’s regulatory authority. The commission reaffirmed its rule. The district court reversed the commission and ordered the commission to regulate maximum hours for the nontransportation workers. The commission appealed.