ABA

ABA Petition Leads to Major Preemption Win as Ninth Circuit Upholds FMCSA Ruling on California Meal and Rest Break Rules 

ABA is pleased to share a significant legal victory for the motorcoach industry. On June 4, the U.S. Court of Appeals for the Ninth Circuit unanimously affirmed the Federal Motor Carrier Safety Administration’s (FMCSA) determination that California’s meal and rest break (MRB) requirements are preempted as applied to passenger-carrying motor carriers under 49 U.S.C. § 31141. 

This decision represents a major win for motorcoach operators and the traveling public, preserving operational flexibility and reinforcing the federal government’s authority to ensure consistent commercial transportation regulations across state lines. 

A Victory Years in the Making 

The decision marks the culmination of a years-long effort led by the American Bus Association. In 2019, ABA petitioned FMCSA to preempt California’s meal and rest break requirements for passenger-carrying motor carriers, arguing that the state rules imposed significant operational burdens on interstate passenger transportation and created an unreasonable burden on interstate commerce. 

FMCSA ultimately agreed with ABA’s position and issued a determination preempting the California requirements. Since then, ABA has remained actively engaged in supporting the industry’s position through the resulting legal challenges, helping defend the federal determination that was affirmed by the Ninth Circuit. 

“From the beginning, ABA understood that this issue was not just about California — it was about whether interstate passenger carriers could operate safely and reliably under a consistent federal framework. As a California-based operator, I have seen firsthand how conflicting state rules can create real operational challenges for motorcoach companies moving passengers across state lines. ABA was right to bring this petition, and the Ninth Circuit’s ruling confirms the importance of FMCSA’s role in protecting safety, operational efficiency, and interstate commerce. This is a meaningful win for operators, drivers, and the traveling public.”

Terry Fischer, President, TCS and Chairman, American Bus Association 

What the Court Decided  

In a unanimous decision, the three-judge panel rejected challenges to FMCSA’s determination that California’s MRB rules should not apply to passenger-carrying commercial motor vehicle operators. 

The court relied heavily on its previous ruling in International Brotherhood of Teamsters, Local 2785 v. FMCSA (2021), which upheld FMCSA’s authority to preempt California’s MRB rules for trucking operations. The panel concluded that arguments seeking to limit FMCSA’s preemption authority had already been resolved by that precedent. 

The court also rejected claims that FMCSA lacked authority to preempt California’s break requirements for bus drivers simply because federal regulations do not impose an equivalent 30-minute rest-break requirement on passenger-carrying drivers. The court found that FMCSA’s authority under federal law is not dependent on the existence of a directly corresponding federal regulation. 

Finally, the court dismissed arguments that FMCSA acted arbitrarily or capriciously in determining that California’s rules imposed an unreasonable burden on interstate commerce.  

Why This Matters   

The central finding of the court’s decision was that the record supports FMCSA’s conclusion that California’s meal and rest break requirements impose a “significant operational burden” on operators of passenger-carrying commercial motor vehicles. The court held that this finding alone was sufficient to justify FMCSA’s decision to preempt the state rules. 

For motorcoach operators, this recognition is critically important. California’s MRB requirements have long created scheduling challenges, route disruptions, compliance complexities, and operational uncertainty for carriers moving passengers across state lines. The court’s decision affirms that these burdens are substantial and that federal law appropriately protects interstate passenger transportation from inconsistent state requirements. 

“ABA is pleased with the Ninth Circuit’s ruling, which confirms that ABA was right to file this petition and right to press for a uniform federal framework for interstate passenger transportation. The court recognized that California’s meal and rest break rules imposed a significant operational burden on passenger carriers, creating scheduling challenges, route disruptions, and compliance uncertainty for operators moving passengers across state lines. FMCSA has a duty to promote safety and to preempt state or local rules when they interfere with safe operations, service reliability, or interstate commerce. This decision is an important win for safety, efficiency, and the motorcoach industry, and it validates ABA’s continued advocacy on behalf of operators and the passengers they serve.”

Fred Ferguson, President & CEO, American Bus Association  

A Win for Safety, Efficiency, and Interstate Commerce 

The ruling reinforces the importance of a uniform federal regulatory framework for passenger transportation. Motorcoach operators depend on predictable scheduling, coordinated driver management, and consistent safety standards to serve passengers effectively and efficiently. 

By affirming FMCSA’s preemption determination, the Ninth Circuit has helped preserve a regulatory environment that supports safe operations while reducing unnecessary compliance burdens that can interfere with service reliability and interstate travel. 

For ABA, the decision also validates years of advocacy on behalf of motorcoach operators seeking regulatory consistency across state lines. The ruling confirms what ABA argued from the outset: that passenger carriers are best served by a uniform federal framework that promotes both safety and operational efficiency. 

ABA will continue advocating for policies that support the growth, safety, and success of the motorcoach industry nationwide.