American Trucking Assns. v. Michigan Public Serv. Commn. & Mid-Con Freight Systems v. Michigan public Serv. Commn. (consolidated)
This case involves the effect of several federal laws on various provisions of Michigan's Motor Carrier Act (MCA). Under the MCA, motor carriers pay a $100 registration fee for an intrastate operating license and a $100 annual fee for administration of the MCA. The annual fee also applies to motor carriers registered in other states that are engaged entirely in interstate commerce. The plaintiffs are a class of motor carriers who challenged the intrastrate registration fee as violating the United States Commerce Clause because it burdens interstate commerce, and the interstate administration fee as having been pre-empted by the Single State Registration System (SSRS), a federal statute that provides for the registration of interstate motor carriers (49 U.S.C. § 14504). The state trial court upheld the fees in the MCA, finding no constitutional violations and no federal pre-emption. The Michigan Court of Appeals affirmed. Regarding the Commerce Clause, the court found that the intrastate registration fee was an even-handed fee that did not discriminate against interstate operators and did not impose an excessive burden. Regarding pre-emption, the court found that the interstate administration fee was not a registration fee but rather a fee related to the administration and enforcement of safety regulations; accordingly, it was not pre-empted by the SSRS, which affects only registration fees.
Questions Presented:
1. Whether the $100 fee upon vehicles conducting intrastate operations violates the Commerce Clause of the United States Constitution.
2. Whether the $100 fee upon vehicles operating solely in interstate commerce is preempted by 49 U.S.C. § 14504.
Supreme Court Opinions
American Trucking Assns. v. Michigan
Public Serv. Commn.
Mid-Con Freight Systems v. Michigan Public Serv. Commn.
