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C.H. Robinson Worldwide, Inc. v. Allen Miller

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 19-15981 · judgment September 28, 2020


Certiorari denied · June 27, 2022
Pre-decision estimate: 12% cert probability (95% interval 9%–17%)

Before the decision, about 3× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Ninth Circuit decision below, and a dissent in the court below (flagged in the petition).

Question presented

Congress enacted the Federal Aviation Administration Authorization Act (FAAAA) to deregulate the trucking industry. The statute preempts a “[state] law, regulation, or other provision” that is “related to a price, route, or service of any motor carrier * * * or * * * broker.” 49 U.S.C. 14501(c)(1). Another provision—commonly known as the “safety exception”—preserves the “safety regulatory authority of a State with respect to motor vehicles.” 49 U.S.C. 14501(c)(2)(A). The question presented is whether a common-law negligence claim against a freight broker is preempted because it does not constitute an exercise of the “safety regulatory authority of a State with respect to motor vehicles” within the meaning of the FAAAA’s safety exception.

Counsel of record

For petitioner
Kannon K. Shanmugam
Paul, Weiss, Rifkind, Wharton & Garrison LLP

For respondent
Rena Mara Leizerman
The Law Firm for Truck Safety

Case

Conference history
Distributed for 3 conferences

Amicus briefs
5 cert-stage · 1 merits
(1 supporting pet./neither)

Proceedings

  1. Jun 27 2022
    Petition DENIED.
  2. Jun 07 2022
    DISTRIBUTED for Conference of 6/23/2022.
  3. Jun 07 2022
    Supplemental brief of petitioner C.H. Robinson Worldwide, Inc. filed. (Distributed)
  4. May 24 2022
    Brief amicus curiae of United States filed.
  5. Oct 04 2021
    The Acting Solicitor General is invited to file a brief in this case expressing the views of the United States.
  6. Jul 07 2021
    DISTRIBUTED for Conference of 9/27/2021.
  7. Jul 07 2021
    Reply of petitioner C.H. Robinson Worldwide, Inc. filed. (Distributed)
  8. Jun 22 2021
    Motion to delay distribution of the petition for a writ certiorari until July 7, 2021 granted.
  9. Jun 18 2021
    Motion of petitioner to delay distribution of the petition for a writ of certiorari under Rule 15.5 from June, 30, 2021 to July 7, 2021, submitted to The Clerk.
  10. Jun 16 2021
    Brief of respondent Allen Miller in opposition filed.
  11. May 19 2021
    Brief amici curiae of National Association of Manufacturers, National Retail Federation, and Chamber of Commerce of the United States of America filed.
  12. May 19 2021
    Brief amicus curiae of Transportation Intermediaries Association, Inc. filed.
  13. May 19 2021
    Brief amici curiae of Leading Industry Freight Brokers filed.
  14. May 19 2021
    Brief amicus curiae of DRI–The Voice of the Defense Bar filed.
  15. May 19 2021
    Brief amicus curiae of Interested Freight Motor Carriers filed.
  16. Apr 26 2021
    Motion to extend the time to file a response is granted and the time is extended to and including June 18, 2021.
  17. Apr 22 2021
    Motion to extend the time to file a response from May 19, 2021 to June 18, 2021, submitted to The Clerk.
  18. Apr 19 2021
    Response Requested. (Due May 19, 2021)
  19. Apr 14 2021
    DISTRIBUTED for Conference of 4/30/2021.
  20. Apr 13 2021
    Blanket Consent filed by Petitioner, C.H. Robinson Worldwide, Inc.
  21. Apr 12 2021
    Waiver of right of respondent Allen Miller to respond filed.
  22. Apr 08 2021
    Petition for a writ of certiorari filed. (Response due May 12, 2021)