American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 429 (2005)
Primary Holding
The flat $100 fee imposed by Michigan on trucks engaged in intrastate commercial hauling does not violate the dormant Commerce Clause, as it is regulatory in nature, applies evenhandedly, and does not impose an unconstitutional burden on interstate trade.
In the case of American Trucking Associations, Inc. v. Michigan Public Service Commission, the Supreme Court decided that a $100 fee imposed by Michigan on trucks operating within the state is legal. This matters because it means states can charge fees for regulating local trucking without violating laws meant to protect interstate commerce. For consumers, this ruling helps ensure that local trucking operations can be regulated for safety and efficiency, which can lead to better service and safer roads, especially when they rely on trucks for deliveries.
AI-generated plain-language summary to help you understand this case
In American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, the underlying dispute arose from a provision in Michigan's Motor Carrier Act that imposed a flat annual fee of $100 on motor carriers operating self-propelled vehicles for intrastate commercial hauling. Petitioners, including USF Holland, Inc., a trucking company that conducted both interstate and intrastate operations, argued that the fee discriminated against interstate carriers because it applied uniformly regardless of the actual usage of intrastate versus interstate routes. They contended that this flat fee created an unconstitutional burden on interstate commerce, as it disproportionately affected those carriers who engaged in both types of hauling. The case progressed through the Michigan court system, where the Michigan Court of Claims dismissed the truckers' claims, stating that the fee was regulatory and aimed at the administration of the Motor Carrier Act, which included safety and insurance regulations. The court also noted that the fee was a legitimate exercise of the state's police power and did not violate the Commerce Clause since it applied only to intrastate commerce. The Michigan Court of Appeals affirmed this decision, indicating that the statute regulated evenhandedly and lacked evidence that the fee impacted route choices for trucking firms. The Michigan Supreme Court subsequently denied the petitioners' request for leave to appeal, leading to the petition for certiorari to the U.S. Supreme Court. The relevant background context includes the broader implications of state-imposed fees on interstate commerce, particularly in the trucking industry, which operates across state lines. The case raised questions about the balance between state regulatory powers and the protections afforded to interstate commerce under the Constitution. The Supreme Court ultimately upheld the Michigan fee, affirming the lower courts' conclusions that the fee did not violate the dormant Commerce Clause.
Whether a flat $100 fee imposed by Michigan on trucks engaging in intrastate commercial hauling violates the dormant Commerce Clause.
The judgment is affirmed.
- Court
- Supreme Court
- Decision Date
- April 26, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
Mid-Con Freight Systems, Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 440 (2005)
Consumer LostThe federal statute regarding interstate commerce pre-empts state registration requirements only if they impose an unreasonable burden, and the Michigan law imposing a $100 annual fee on trucks operating entirely in interstate commerce does not constitute such a burden, thus it is not pre-empted by federal law.
United Haulers Assn., Inc. v. Oneida-Herkimer Solid Waste Management Authority, 550 U.S. 330 (2007)
Consumer LostFlow control ordinances that require trash haulers to deliver waste to facilities owned and operated by a state-created public benefit corporation do not violate the Commerce Clause, as they do not discriminate against interstate commerce and serve a legitimate governmental purpose in managing solid waste.
Rowe v. New Hampshire Motor Transp. Assn., 552 U.S. 364 (2008)
Consumer LostThe federal law pre-empts state laws that regulate the delivery of tobacco products when those regulations are related to the price, route, or service of motor carriers, as established by the Federal Aviation Administration Authorization Act of 1994.
DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (2006)
Consumer LostTaxpayers do not have standing to challenge state tax benefits under the Commerce Clause when they claim that such benefits increase their tax burdens, as they cannot demonstrate a concrete and particularized injury that is fairly traceable to the challenged conduct.