Mid-Con Freight Systems, Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 440 (2005)
Primary Holding
The 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.
In the case of Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission, the Supreme Court decided that a Michigan law requiring trucks that only operate across state lines to pay a $100 annual fee was not an unreasonable burden on interstate commerce. This matters because it means states can impose certain fees on trucking companies without conflicting with federal laws, as long as those fees are not excessively high. For consumers, this case is relevant when considering how trucking fees might affect shipping costs or services, as it helps clarify that states can still regulate and charge for trucking operations within their borders.
AI-generated plain-language summary to help you understand this case
In *Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission*, the dispute arose from a Michigan law that imposed an annual fee of $100 on each truck with Michigan license plates operating entirely in interstate commerce. This law was challenged on the grounds that it conflicted with a federal statute, which states that a state registration requirement becomes an unreasonable burden on interstate commerce if it imposes excessively high fees. The central question was whether the Michigan fee constituted a "State registration requirement" under the federal statute, which would trigger preemption. The case reached the Supreme Court after Mid-Con Freight Systems, Inc. and other petitioners contested the Michigan law in lower courts, arguing that the fee exceeded the limits set by federal law. The Michigan Court of Appeals upheld the state law, leading to the petitioners seeking a writ of certiorari to the Supreme Court. The Supreme Court's decision on June 20, 2005, addressed the preemption issue, ultimately concluding that the Michigan fee did not fall under the federal statute's definition of a state registration requirement, and therefore, the federal law did not preempt the state law. The background context includes the evolution of federal and state regulations governing interstate trucking. Federal law has long required motor carriers engaged in interstate commerce to obtain a Federal Permit. In 1991, Congress enacted the Single State Registration System (SSRS) to streamline the registration process for interstate trucking, limiting state fees to a maximum of $10 per truck. The Michigan law's $100 fee was significantly higher than this federal limit, prompting the legal challenge and raising questions about the balance of state and federal authority in regulating interstate commerce.
Whether the federal statute regarding state registration requirements for interstate commerce preempts a Michigan law imposing an annual fee on trucks operating entirely in interstate commerce.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- April 26, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, 545 U.S. 429 (2005)
Consumer LostThe 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.
Granholm v. Heald, 544 U.S. 460 (2005)
Consumer WonState laws that allow in-state wineries to sell wine directly to consumers while prohibiting or restricting out-of-state wineries from doing the same violate the Commerce Clause of the Constitution, and such discrimination is not permitted by the Twenty-first Amendment.
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.
Wagnon v. Prairie Band Potawatomi Nation, 546 U.S. 95 (2005)
Consumer LostThe application of the Kansas motor fuel tax to fuel received by non-Indian distributors, which is subsequently delivered to a gas station on the Prairie Band Potawatomi Nation's reservation, does not violate the Nation's sovereignty because the tax arises from a transaction that occurs off the reservation, and thus the Bracker interest-balancing test does not apply.