Yellow Transportation, Inc. v. Michigan
The Supreme Court sided with a federal agency's rule that states participating in a national truck-registration fee system had to honor the fee waivers and discounts they had given other states under reciprocity agreements as of November 1991, rather than letting them retroactively charge full fees.
The ruling reversed Michigan's top court, which had said only a state's generic, undiscounted fee mattered, and it reinforces how much deference federal courts give agencies when a statute leaves gaps for them to fill.
How it got here: Michigan's Court of Claims and Court of Appeals ruled for the trucking company; the Michigan Supreme Court reversed, and the Supreme Court granted certiorari to review that reversal.
The Case in Depth
What happened
A Kansas-based trucking company paid Michigan a $10-per-vehicle registration fee for 1992 that it had not been charged in prior years, after Michigan changed how it determined which out-of-state carriers qualified for fee waivers under its reciprocity arrangements with other states. The company sued for a refund, arguing a new federal law capped Michigan's fees at whatever it actually collected or charged as of November 15, 1991 — which, for this company's vehicles, was zero.
The question before the Court
When a federal law froze state truck registration fees at what a state "collected or charged" as of November 15, 1991, could a state count fees it had waived under reciprocity deals with other states?
Why it matters
Interstate trucking companies that benefited from fee waivers or discounts under state reciprocity deals keep that lower fee level, preventing states from unilaterally raising truckers' costs by hundreds of percent. The decision also reaffirms that agencies like the old Interstate Commerce Commission can resolve gaps Congress left in complex regulatory statutes, guiding how similar interstate fee and permitting disputes get decided.
What changes now
The case returns to the Michigan Supreme Court to apply the now-confirmed rule that reciprocity-agreement fees count toward the November 1991 baseline. That court still must resolve issues it hadn't reached, including whether the fees the trucking company paid for the 1992 registration year actually reflect the 1991 baseline and whether Michigan had already canceled its reciprocity agreements in 1989. This is a final merits ruling on the legal question, not a temporary order.
What this does not decide
The Court did not decide whether the specific fees the trucking company paid for 1992 actually equaled the November 1991 baseline, or whether Michigan had canceled its reciprocity agreements back in 1989 — both questions were left for the Michigan Supreme Court on remand.
Concurrences and dissents
Concurrence — Justice Stevens
Justice Stevens argued the statute was not actually ambiguous: Michigan's basic fee system (a $10 cap, same vehicles covered, same reciprocity partners) stayed the same before and after November 1991, so the fee-cap language alone didn't require freezing reciprocity terms. Instead, he concluded the agency's power to freeze reciprocity agreements came from Congress's broader delegation to the agency to design a fee system that avoided burdening interstate commerce, not from the specific fee-cap clause the majority relied on.
How the Court got there
The legal reasoning, step by step
- The Court applied the two-step framework from Chevron U.S.A. Inc. v. Natural Resources Defense Council for reviewing an agency's interpretation of a statute it administers: first ask whether Congress spoke clearly to the exact issue, and if not, defer to any reasonable agency reading.
- The Court found the statutory phrase 'collected or charged as of November 15, 1991' ambiguous, since it could mean either the fee a state actually collected from a given carrier (which could be zero under a reciprocity waiver) or a generic, undiscounted fee the state had on its books.
- Because Congress had expressly directed the agency to design the fee system through formal notice-and-comment rulemaking, the Court treated the agency's interpretation as entitled to Chevron deference rather than a lesser form of review.
- The Court concluded that reading 'collected or charged' to mean the fee actually collected, including zero where a reciprocity waiver applied, was a permissible and reasonable interpretation, especially since the agency was concerned that letting states disavow reciprocity deals could cause fees and state revenues to spike dramatically.
- Having found the statute ambiguous and the agency's fee-freezing interpretation reasonable, the Court held that interpretation controlling and rejected the Michigan Supreme Court's contrary reading that only a generic statewide fee mattered.
Doctrinal impact
Cases affected by this decision
Reaffirms Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (467 U.S. 837)
The Court applied Chevron's two-step deference framework to uphold the agency's interpretation of the fee-cap statute.