Appeals Court Sides With FMCSA in Battle Over California’s Meal and Rest Break Rules

Sacramento, CA – The 9th U.S. Circuit Court of Appeals has issued its decision in favor of the Federal Motor Carrier Safety Administration’s (FMCSA) preemption of California’s meal and rest break (MRB) requirements for professional drivers.

In an opinion issued by Judge Daniel Bess, the panel determined the FMCSA “did not act arbitrarily or capriciously in finding that enforcement of the MRB rules ‘would cause an unreasonable burden on interstate commerce.’”


The International Brotherhood of Teamsters filed suit against FMCSA in February of 2019 after the Agency issued its preemption order in December 2018.

“California’s law is incompatible with Federal regulations and causes a disruption in interstate commerce,” then-FMCSA Administrator Ray Martinez said at the time. “In addition, the confusing and conflicting requirements are overly burdensome for drivers and reduce productivity, increasing costs for consumers. Additionally, safety issues have likely resulted from the lack of adequate parking solutions for trucks in the State.”

The Teamsters’ lawsuit asked the court to reverse the decision “due to the adverse impact it would have on thousands of workers and highway safety in California.”


In the Court’s 34-page opinion issued on Friday, Judge Bess wrote, “The panel concluded that the FMCSA permissibly determined that California’s MRB rules were State regulations ‘on commercial motor vehicle safety,’ so that they were within the Agency’s preemption authority.”

California’s law required employers to provide a 30-minute meal break for employees who work more than five hours a day, as well as a second 30-minute meal break for those who work more than 10 hours a day.

Moreover, employers were required to provide additional 10-minute rest periods every four hours.

The MRB requirements were substantially more strict than the federal hours-of-service (HOS) regulations.


The MRB rules frustrated many carriers operating in California because it opened them up to more complexity, compliance costs and a series of class action lawsuits.

The Agency’s preemption order was celebrated by the American Trucking Associations (ATA) and the Specialized Carriers and Rigging Association which both submitted petitions arguing California can’t preempt federal regulations that govern federal HOS regulations.

Today’s decision will be cheered among many trucking stakeholders.


At time of publishing the Teamsters had not yet released a statement in response to the ruling.

We will update this article if/when they do.

It also remains to be seen if the new incoming Biden Administration’s FMCSA will rescind the preemption order.



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