By: Monica Folsom
On June 4, 2026, in People v. FMCSA, the Ninth Circuit held that the Federal Motor Carrier Safety Administration (“FMCSA”) properly preempted California’s meal and rest break (“MRB”) rules as applied to passenger-carrying commercial motor vehicles. Upon a finding that a state law or regulation is additional to or more stringent than a federal regulation on commercial motor vehicle safety, the Secretary of Transportation has the power to preempt state laws that have no safety benefit, are incompatible with federal regulation, or cause an unreasonable burden on interstate commerce.
Federal hours-of-service (“HOS”) regulations govern when drivers of passenger-carrying commercial motor vehicles must stop driving and take off-duty time. California’s MRB rules separately require meal periods and rest breaks. The FMCSA concluded that California’s MRB rules as applied in this context were more stringent than the federal requirements, did not provide any measurable safety benefit, were incompatible with federal regulation, and imposed an unreasonable burden on interstate commerce.
The Ninth Circuit upheld the FMCSA’s determination, relying in part on its earlier decision in International Brotherhood of Teamsters, Local 2785 v. Federal Motor Carrier Safety Administration, 986 F.3d 841 (9th Cir. 2021). In Teamsters, the court held that the FMCSA acted within its authority and reasonably found that additional state break requirements, like California’s MRB rules, would disrupt the uniformity of regulation as to commercial drivers operating in interstate commerce. Because California’s MRB rules and the federal HOS regulations share the same purpose of mandating off-duty periods as a form of ensuring commercial motor vehicle safety, the MRB rules are within the FMSCA’s domain.
In analyzing the People’s argument that the FMCSA acted arbitrarily and capriciously in finding an unreasonable burden would be caused, the court looked to the administrative record and determined that there was ample support to demonstrate that imposing such a vast array of rules on drivers would be disruptive and costly. Notably, the court reasoned that the effects of these sweeping regulations would change the fundamental nature of bus service. Therefore, California’s MRB rules are preempted for drivers of passenger-carrying commercial motor vehicles subject to federal HOS regulations.
This decision mandates that drivers be provided with breaks as required under federal HOS regulations only. Despite operating in California, companies employing drivers of passenger-carrying commercial motor vehicles are not required to offer them breaks as outlined in California’s MRB rules. It also reaffirms the court’s decision in Teamsters that only federal HOS regulations apply to commercial drivers operating in interstate commerce.
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