A federal court in California recently dismissed with prejudice a wage and hour putative class action brought by truck drivers, alleging claims based on violations of California's meal break laws, on the ground that those laws (as applied to a motor carrier's truck drivers) are preempted by the Federal Aviation Administration Authorization Act (FAAAA). See Esquivel et al. v. Vistar Corp. et al., Case No. 2:11-cv-07284 (C.D. Cal. Feb. 8, 2012). In making that ruling, the Esquivel court became the second court in recent months to hold that California's break laws are preempted by the FAAAA, which expressly preempts state laws that have a significant impact on the routes, service or prices of motor carriers.
Case Background
The plaintiffs in Esquivel were former truck drivers of various divisions of Performance Food Group, Inc. (PFG) in California. They alleged that PFG built its delivery routes to ensure timely delivery and customer service, but did so by...
