Mid-Con Freight Systems, Inc. v. Michigan Public Service Commission

Background

Interstate trucking companies with Michigan license‑plated trucks challenged a Michigan law that charges a $100 annual fee for each truck operating entirely in interstate commerce. The companies asked state courts to invalidate the fee under a federal law that created a Single State Registration System (SSRS) for showing proof of a federal permit, proof of insurance, and a local agent for service of process. Lower Michigan courts refused relief, the Michigan Supreme Court denied review, and the companies sought review here.

Reasoning

The key question was whether the federal SSRS law overrides Michigan’s $100 fee. The majority read the federal statute’s text, history, and purpose to limit federal override to state requirements that deal with the SSRS subject matter—proof of the federal permit, insurance filings, and agent designation—and only to the extent a State’s rule exceeds SSRS limits. The Court found Michigan’s $100 fee does not require those specific filings, existed before the SSRS, and does not prevent a carrier from completing SSRS registration, so the federal law does not override the Michigan fee. Justice Breyer wrote the opinion; five Justices joined; Justice Kennedy dissented.

Real world impact

Truck owners with Michigan plates generally remain subject to the $100 annual charge. The decision narrows federal override to the SSRS’s limited list of registration items, leaving many other state truck fees and decals untouched. This ruling resolves this dispute but does not decide every possible state fee conflict under federal law.

Dissents or concurrances

Justice Kennedy (joined by Chief Justice Rehnquist and Justice O’Connor) disagreed, arguing the statute should broadly bar state registration requirements that single out interstate carriers and favored further review or remand.