07-1402 Aux Sable Liquid Products v. Murphy

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Transportation
STAA; preemption

The Surface Transportation Assistance Act preempts local laws denying access to interstate highways.

"[W]e agree with the district court that Congress's primary objective in passing the STAA was to create uniform standards for commercial motor vehicles utilizing the Interstate and other federal highways. Congress also recognized that this goal would be frustrated if commercial motor vehicles validly permitted on the Interstate were barred by state and local governments from entering the Interstate on local roads or exiting the Interstate for purposes of refueling or delivering goods. Thus, § 31114 prohibits states from denying commercial motor vehicles 'reasonable access' to and from the Interstate. Congress's decision not to define "reasonable access" more specifically does not mean that states are permitted to define the term however they see fit. Rather, this broad language can be viewed as reflecting a recognition on Congress's part that the manner and degree of access to and from the Interstate necessary to protect Congress's overarching goal of uniformity for commercial motor vehicles utilizing the Interstate will vary across the country depending on factors such as whether the Interstate is cutting across rural or metro areas, traffic density on the road, and other considerations. See New Hampshire Motor Transp. Ass'n., 67 F.3d at 330 (opining that it would be within a state or local government's discretion, in accord with the 'reasonable access' provision under § 31114(a), to impose 'a restriction that routed heavy traffic on a detour of a few miles to assure quiet in a hospital zone'). Under this framework, states are still free to exercise their police powers over state highways and local roads, so long as these regulations do not impede 'reasonable access' for commercial motor vehicles traveling between the Interstate and places such as terminals."

Affirmed.

07-1402 Aux Sable Liquid Products v. Murphy

Appeal from the United States District Court for the Northern District of Illinois, Kocoras, J., Flaum, J.

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