MID-CON FREIGHT SYSTEMS, INC. v. MICHIGAN PUB. SERV. COMM'N

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Case Basics
Docket No. 
03-1234
Petitioner 
Mid-Con Freight Systems, Inc., et al.
Respondent 
Michigan Public Service Commission, et al.
Consolidation 
American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, No. 03-1230
Advocates
(argued the cause for Respondents)
(argued the cause for Respondents)
(argued the cause for Petitioners in 03-1234)
(argued the cause for Petitioners in 03-1230)
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Facts of the Case 

A Michigan law imposed an annual $100 fee on each Michigan license-plated truck that operated entirely in interstate commerce. A group of interstate trucking companies sought unsuccesfully to have Michigan courts invalidate the law. The companies claimed that the federal law that had created the Single State Registration System (SSRS) preempted and prohibited such state fees. Under the federal law a trucking company could obtain a permit applicable in every state by registering once in a single state. While the initial state could demand a fee equal to the sum of its individual state fee, the law prohibited a state from imposing an additional "state registration requirement."

Question 

Did federal law establishing for trucks the Single State Registration System (SSRS) preempt a separate Michigan registration fee?

Conclusion 
Decision: 6 votes for Michigan Pub. Serv. Comm'n, 3 vote(s) against
Legal provision: 49 U.S.C. 14504

No. In a 6-3 opinion delivered by Justice Stephen Breyer, the Court held that "reference to text, historical context, and purpose" proved that the words "state registration requirement" in the federal law applied only to state requirements concerning SSRS registration. The Michigan statute, the majority reasoned, had nothing to do with SSRS.

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MID-CON FREIGHT SYSTEMS, INC. v. MICHIGAN PUB. SERV. COMM'N. The Oyez Project at IIT Chicago-Kent College of Law. 20 June 2014. <http://www.oyez.org/cases/2000-2009/2004/2004_03_1234>.
MID-CON FREIGHT SYSTEMS, INC. v. MICHIGAN PUB. SERV. COMM'N, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2004/2004_03_1234 (last visited June 20, 2014).
"MID-CON FREIGHT SYSTEMS, INC. v. MICHIGAN PUB. SERV. COMM'N," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 20, 2014, http://www.oyez.org/cases/2000-2009/2004/2004_03_1234.