Tillison

Appellant-Plaintiff John Tillison d/b/a West Coast Towing Services (“Tillison”) challenges Revised Code of Washington section 46.55.080(2), which restricts patrol and non-consensual towing by: (1) requiring a towing company to obtain written authorization from a private property owner before towing a vehicle from the private property, or from a public official before towing a vehicle from public property, without the vehicle owner’s permission; (2) requiring the private property owner or the public official be present for the tow; and (3) prohibiting the towing company from serving as an agent for the private property owner or the public official. Tilli-son claims that Revised Code of Washington section 46.55.080(2) is preempted by the Federal Aviation Administration Authorization Act of 1994 (“FAAAA”), Pub.L. No. 103-305, § 601 (c), 108 Stat. 1569 , 1606, 49 U.S.C. §§ 14501-14505 , which governs the prices, routes, or services of motor carriers transporting property (including tow truck operators). Tillison was recently unsuccessful in a similar challenge of a similar California law regulating patrol and non-consensual towing. See Tillison v. City of San Diego, 406 F.3d 1126 (9th…