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Massachusetts Delivery Association v. Coakley, No. 13-2307 (September 30, 2014)

Articles Discussing Case:

First Circuit Favors Broad Application of Analogue to Airline Deregulation Act Preemption Provision

Ogletree Deakins • October 07, 2014
On September 30, 2014, in Massachusetts Delivery Association v. Coakley, No. 13-2307 (September 30, 2014), the First Circuit Court of Appeals overturned a lower court’s refusal to preempt a Massachusetts independent contractor law under the express preemption provision of the Federal Aviation Administration Authorization Act (FAAAA). The FAAAA’s preemption provision, which prohibits state and local regulation related to prices, routes, or services of motor carriers, was substantially derived from the express preemption provision of the Airline Deregulation Act (ADA), which applies to air carriers. Courts regularly rely on cases decided under the FAAAA in interpreting the ADA preemption provision, and vice versa. Thus, the Massachusetts Delivery Association (MDA) case has significant implications for air carriers as well as motor carriers.