California Court of Appeals Rules Short Haul Drivers’ Claims Preempted by Federal Motor Carrier Safety Administration Rules
In Espinoza v. Hepta Run, Inc., the California Court of Appeal reiterated that federal law preempts California meal and rest period requirements for motor carriers and confirmed such preemption also applies to short-haul drivers.
A truck driver filed a complaint against his employer alleging various wage and hour violations, including failure to provide meal and rest periods. In 2019, the employer filed a motion for summary adjudication as a matter of law to dispose of the meal and rest period claim, arguing that California’s statutes governing meal and rest periods were preempted by federal regulations concerning commercial motor vehicle safety. The trial court denied the motion and the matter proceeded to a bench trial. At the bench trial, the employer was found liable for California Labor Code violations.
The employer appealed. The California Court of Appeal then considered whether the trial court erred in denying the dispositive motion pertaining to the alleged failure to provide meal and rest periods.
In 2021, the U.S. Court of Appeals for the 9th Circuit had held that the Federal Motor Carrier Safety Administration (FMCSA) is responsible for regulating commercial motor carrier safety and that federal law preempts California’s meal and rest break rules. In this appeal, the plaintiff-truck driver argued that the preemption did not apply to him as a short-haul driver because short-haul drivers are exempted from the 30-minute rule break under federal regulations.
The Court of Appeal found for the employer, holding “[i]t is undisputed that certain [federal] hours of service rules apply to short-haul drivers, such as the daily limits on driving time and the daily and weekly limits on on-duty time. Thus the [hours of service] rules, as a general matter, apply to short-haul drivers. The fact that such drivers are exempted from one rule does not remove them from the universe of drivers subject to the hours of service rules, and it is not reasonable to read the language of the [FMCSA] order to suggest they are.” Based on its finding that preemption by federal regulations applied to the plaintiff’s claim, the Court of Appeal reversed the denial of the employer’s motion for summary judgment. In so doing, the trial court’s later judgment for the driver was overturned, as well.
This ruling provides more clarity to motor carriers in the state as to the application of the federal preemption to California’s meal and rest break requirements.