H. P. Welch Co. v. New Hampshire

Background

A Massachusetts trucking company that hauled freight mostly between states challenged parts of a New Hampshire law. The State required carriers to register trucks and forbade any driver from operating a vehicle after being continuously on duty for more than twelve hours, with at least eight consecutive hours off required before returning to duty. The company had registration certificates suspended after the state commission found violations of the hours rule, and the New Hampshire Supreme Court upheld that action.

Reasoning

The Court addressed two simple questions: whether the State’s limit treated drivers unfairly, and whether the federal Motor Carrier Act and pending federal rules prevented the State from enforcing its safety law. The Justices accepted the State’s safety purpose and found the classification reasonably related to protecting highway users from fatigued drivers, so equal protection was not violated. The Court also held that Congress’s grant of regulatory power to the Interstate Commerce Commission did not clearly show an intent to displace state safety laws before federal rules actually took effect. Because the federal hours regulations cited were authorized but not yet operative, New Hampshire’s provisions remained enforceable for the violations here.

Real world impact

For now, states can enforce reasonable limits on how long truck drivers operate on state roads, even for carriers that also do interstate business. The opinion leaves open that later, when valid federal hours rules become effective, they may override state rules, but a clear federal intent to displace local safety measures is required.