Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission
The Court ruled that a federal law simplifying how interstate trucking companies register with states does not stop Michigan from charging its own separate $100 annual fee on Michigan-plated trucks that operate purely across state lines.
The decision narrows the reach of a federal preemption clause, holding it only blocks state rules tied to the specific paperwork the federal system covers -- proof of a federal permit, proof of insurance, and a local agent for legal papers -- not unrelated state fees.
“We conclude that the Michigan fee requirement is not the kind of “State registration requirement” to which the federal statute refers.”
The Court's core holding that Michigan's fee escapes federal preemption.
How it got here: Michigan's courts rejected the trucking companies' preemption claim; they asked the Supreme Court to review after the state supreme court declined to hear a further appeal.
The Case in Depth
What happened
Federal law lets an interstate trucking company register its federal operating permit once, in one state, instead of filing separately in every state it drives through. Michigan separately charged trucking companies with Michigan-plated trucks an annual $100 fee for trucks operating entirely in interstate commerce. Several trucking companies argued this state fee was blocked by the federal registration law and sued to have it struck down.
The question before the Court
Does a federal law meant to simplify interstate trucking permits also block Michigan from charging its own $100-per-truck fee?
The Court's answer
No — the Court ruled that the federal law's ban on extra "State registration requirements" only reaches state rules tied to the same subject matter as the federal single-state system: proof of a federal operating permit, proof of insurance, and naming a local agent for legal papers. Michigan's $100 fee touches none of that; it requires different information, existed before the federal system was created, and only loosely connects to it through a small fee credit.
Because the fee falls outside that narrow zone, the federal law doesn't block it. The Court left standing the Michigan Court of Appeals' judgment upholding the fee, though on different reasoning than that court used.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Trucking companies operating Michigan-plated vehicles must keep paying the $100 fee on top of any federal registration costs, and states retain room to impose their own registration-style fees on interstate carriers as long as those fees don't duplicate the specific paperwork the federal single-state system covers.
What changes now
This is a final merits decision resolving the preemption question, so Michigan's $100 fee stands and the Michigan Court of Appeals' judgment is affirmed. The ruling also guides how this and other preemption clauses in the federal trucking-registration law will be read in future disputes, though it leaves open how courts should handle related arguments -- such as whether Michigan's fee should be compared against its own intrastate truck fee -- that the dissent flagged as unresolved.
What this does not decide
The Court did not decide whether Michigan's $100 fee is unconstitutional under the Commerce Clause on its own terms, nor whether the fee is valid when compared to Michigan's separate fee on intrastate trucks -- an argument the dissent said should be addressed on remand rather than resolved here.
Concurrences and dissents
Dissent — Justice Kennedy
Justice Kennedy argued the majority's narrowing of 'State registration requirement' has no basis in the statutory text, which he read as preempting any state registration requirement not authorized under the federal single-state system. He would have vacated and remanded, since the Michigan Court of Appeals also erred by treating the fee as merely 'regulatory' rather than a registration requirement, leaving unresolved arguments about Michigan's intrastate fee for the lower courts to consider.
How the Court got there
The legal reasoning, step by step
- The Court read the federal statute's two key sentences together: the first sentence protects a state's registration system only when it follows the Secretary of Transportation's standards for the single-state registration system, meaning it addresses proof of a federal permit, proof of insurance, and a local legal-service agent.
- Because the first sentence's phrase 'State registration' is tied to that specific paperwork, the Court reasoned the second sentence's near-identical phrase 'State registration requirement' -- which spells out what excess requirements are barred -- must carry the same narrow meaning rather than a broader one.
- The Court looked at the older 'bingo card' system the new law replaced, noting that system never blocked states from charging unrelated fees or requiring unrelated filings, and found nothing showing Congress meant to expand that reach when it modernized the system.
- The Court considered the law's stated purpose -- making the permit-registration process more efficient and uniform -- and found nothing suggesting Congress intended to sweep in state fees that have nothing to do with permits, insurance, or service-of-process filings.
- Applying that narrow reading to Michigan's $100 fee, the Court found it required none of the federally covered filings, existed before the federal system was created, and only loosely overlapped with the federal system through a minor fee credit -- so it fell outside what the federal law preempts.