Justia California Court of Appeals Opinion SummariesArticles Posted in Transportation Law
Vargas v. FMI, Inc.
Vargas and Villalobos were driving a tractor-trailer across the country. Villalobos was driving and Vargas was in the sleeper berth when the tractor-trailer rolled over, injuring Vargas. Vargas sued FMI (the motor carrier and trailer owner), Eves (the tractor owner), and Villalobos for negligence. The trial court granted summary judgment for FMI and Eves, concluding as a matter of law that neither was vicariously liable for Villalobos’s alleged negligence. The court of appeal reversed. Federal law requires motor carriers using leased vehicles to “have control of and be responsible for” such vehicles (49 U.S.C. 14102) in order to “protect the public from the tortious conduct of the often judgment-proof truck lessor operators.” Defendants did not establish as a matter of undisputed fact that the tractor’s owner is entitled to the protection of the “Graves Amendment,” 49 U.S.C. 30106(a), which shields owners of leased vehicles “engaged in the business or trade of renting or leasing motor vehicles” from vicarious liability for the alleged negligence of their lessee’s drivers. View "Vargas v. FMI, Inc." on Justia Law
Union Pacific Railroad v. Santa Fe Pacific Pipelines
This appeal arose out of a declaratory relief action where the Railroad sought a determination of the rent due from the Pipeline for the continued use of its easements from 2004 to 2014. The Railroad obtained a declaration that the rent due was in excess of $14 million per year. The trial court entered judgment reflecting the total back rent due, plus interest, up to the date of entry of judgment. The Pipeline appealed. The court addressed the law relating to railroad rights-of-way in an effort to resolve the legal issues that apply to property interests in the land and, by extension, the Railroad's right to grant and lease subsurface easements to the Pipeline. The court reversed and remanded the trial court's finding as to the "total fee value" for purposes of its ATF calculation; directed the trial court to determine the total fee value of those parcels of land in which the Railroad had sufficient interest to entitle it to collect rent on the Pipeline's easements between January 1, 2004, and December 31, 2013; concluded that the trial court committed no error with respect to its determinations regarding issue preclusion, use of the ATF method, - calculations of the rental rate, the enhancement factor, and the use factor -, and the dates of abandonment of certain easements by the Pipeline; and reversed and remanded that part of the judgment awarding prejudgment interest under Civil Code 3287(a) in order for the trial court to determine whether the Pipeline was liable for the payment of rent on the reserved easements, the abandoned easements, or Line Section 101, which rent it unilaterally withheld.View "Union Pacific Railroad v. Santa Fe Pacific Pipelines" on Justia Law
Friends of the Eel River v. N. Coast RR. Auth.
North Coast Railroad Authority (NCRA), a public agency established by Government Code section 93000, entered into a contract with the Northwestern Pacific Railroad Company (NWPRC), allowing NWPRC to conduct freight rail service on tracks controlled by NCRA. Two environmental groups filed suit under the California Environmental Quality Act (CEQA), Pub. Resources Code, 21050, 21168.5, to challenge NCRA’s certification of an environmental impact report (EIR) and approval of NWPRC’s freight operations. The trial court denied the petitions, concluding CEQA review was preempted by the Interstate Commerce Commission Termination Act (ICCTA; 49 U.S.C. 10101) and rejecting a claim that NCRA and NWPRC were estopped from arguing otherwise. The appeals court affirmed, rejecting an argument that the ICCTA preempts only the “regulation” of rail transportation, whereas NCRA agreed to conduct a CEQA review of the rail operations and related repair/maintenance activities as part of a contract allowing it to receive state funds. NCRA and NWPRC are not estopped from claiming no EIR was required, due to positions taken in previous proceedings and the EIR was not insufficient for improperly “segmenting” the project, given that additional rail operations were contemplated on other sections of the line. View "Friends of the Eel River v. N. Coast RR. Auth." on Justia Law