Owner-Operator Independent Drivers Ass'n v. Swift Transportation Co.

The plaintiffs in this class action are independent truck drivers, known in the trucking industry as “owner-operators,” and an association of owner-operators. Defendants are federally regulated motor carriers that contract with owner-operators to transport cargo across the country. Federal “Truth-in-Leasing” regulations require that motor carriers and owner-operators enter into written leases that explicitly address certain contractual issues, such as compensation and duration. Plaintiffs contended that defendants’ standard form lease agreements failed to comply with the Truth-in-Leasing regulations in various respects, and moved for a preliminary injunction. The district court applied the “traditional” balancing test to the motion, and denied it.

Plaintiffs appeal, asserting that the district court committed an error of law by applying the traditional equity balancing test to their motion. They contend that the district court should have granted the motion for injunctive relief upon a showing of “reasonable cause” to believe that defendants’ leases violated the Truth-in-Leasing regulations. We disagree. The proposed “reasonable cause” test applies only when Congress…