Valiente v. Swift Transp. Co.

The Supreme Court has provided a two-prong test for determining when the doctrine of anti-retroactivity applies: (1) a court must determine whether Congress has expressly prescribed the statute's proper reach; and (2) a court must assess whether the action would have an impermissible retroactive effect. Landgraf v. USI Film Products, 511 U.S. 244, 263-64, 280 (1994).

In 2018, the Federal Motor Carrier Safety Administration (FMCSA) decided to preempt California's meal and rest break (MRB) rules in regards to truck drivers subject to federal regulations, which was determind by this Court to be a lawful exercise of power under the Motor Carrier Safety Act of 1984 (MCSA). See Int'l Brotherhood of Teamsters, Local 2785 v. FMCSA, 986 F.3d 841, 846 (9th Cir. 2021). Appellants appealed summary judgment dismissing their action for violation of California's MRB rules, which had been brought prior to the preemption by FMSCA. Appellants argued that the presumption against retroactive application of laws should allow their suit to proceed despite FMSCA's preemption. The Supreme Court has provided a two-prong test for determining when the doctrine of anti-retroactivity applies: (1) a court must determine whether Congress has expressly prescribed the statute's proper reach; and (2) a court must assess whether the action would have an impermissible retroactive effect. Landgraf v. USI Film Products, 511 U.S. 244, 263-64, 280 (1994). The Court reasoned that Congress' intention was for the FMCSA to have the power to halt enforcement of state laws. As such, evaluation of the second prong of the test was unnecessary and the FMCSA's decision to preempt prohibits enforcement of California's MRB rules, regardless of when the suit was originally brought or the underlying conduct occurred. Affirmed.