Maurer v. Hamilton
Headline: Court upholds Pennsylvania ban on carrying cars above truck cabs, ruling the federal Motor Carrier Act and ICC safety rules do not override state size-and-weight highway safety regulations.
Holding: The Court held that Pennsylvania’s law banning cars carried above truck cabs is a regulation of size and weight reserved to the state and is not superseded by the Motor Carrier Act or Commission rules.
- Leaves states able to ban carrying vehicles above truck cabs for highway safety.
- Prevents ICC or the Motor Carrier Act from automatically overriding state size-and-weight rules.
- Keeps safety regulation local until federal investigation and report are completed.
Summary
Background
A group of motor carriers that transport new cars on specially built trucks sued state officers to stop enforcement of a Pennsylvania law (§1033(c)) that bans carrying another vehicle above a truck driver’s cab. Trial and state supreme courts found the practice dangerous in Pennsylvania because it raises the load’s center of gravity, obstructs the driver’s view, worsens steering and braking, and can cause serious injuries in collisions. Meanwhile, the Interstate Commerce Commission (ICC) had safety regulations for interstate carriers but no rule specifically banning car-over-cab loading and issued a report saying the practice did not appear unsafe.
Reasoning
The core question was whether Congress and the Motor Carrier Act gave the ICC power to override state rules about how vehicles and their loads are sized and weighted. The Court examined two parts of the Act: one giving the ICC authority over “safety of operation and equipment,” and another (§225) reserving investigation of “sizes and weight” to the Commission and Congress. The Court found the Pennsylvania law to be a regulation of size, weight, and weight distribution — matters §225 reserved to the states pending federal study. Because §225 was meant to preserve state power over these load dimensions until the federal investigation and report were complete, the state law was not displaced by the Act or the ICC’s existing regulations.
Real world impact
The decision leaves states free to set limits on load height and weight distribution for safety unless and until Congress or the ICC, after investigation, clearly takes that authority. Motor carriers operating in states with local safety rules must follow those state limits in the meantime.
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