People Ex Rel. Harris v. Pac Anchor Transportation, Inc.

The narrow question presented is whether an action under the unfair competition law (Bus. & Prof. Code, § 17200 et seq. (UCL)) that is based on a trucking company’s alleged violation of state labor and insurance laws is “related to a price, route, or service” ( 49 U.S.C. § 14501 (c)(1)) of the company and, therefore, preempted by the Federal Aviation Administration Authorization Act of 1994 ( Pub.L. No. 103-305 (Aug. 23, 1994) 108 Stat. 1569 ) (FAAAA). The FAAAA provides that a state “may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier . : . with respect to the transportation of property.” ( 49 U.S.C. § 14501 (c)(1).) The People, on behalf of the State of California, filed this action against defendants Pac Anchor Transportation, Inc. (Pac Anchor), and Alfredo Barajas (Barajas) for misclassifying drivers as independent contractors and for other alleged violations of California’s labor and unemployment insurance laws. As we explain, we conclude that the FAAAA does not preempt the People’s UCL action against defendants. We therefore affirm the Court of Appeal’s…