MCA Exemption Applies to Intrastate Shuttle Legs Between Off-Site Storage Lots and Final Assembly Plant Destination

Introduction

In Renee Stingley, et al. v. L ACI Transport Inc., et al. and Martaneze Johnson, et al. v. B OSMAN TRUCKING, INC., et al., consolidated on appeal, the Seventh Circuit addressed whether Illinois-based “shuttle” truck drivers—who drove only intrastate routes—were entitled to overtime under the Fair Labor Standards Act (“FLSA”) or were instead exempt under the Motor Carrier Act (“MCA”) exemption.

The plaintiffs were current and former shuttle drivers moving trailers of automobile parts that were manufactured outside Illinois and brought to Ford-controlled storage lots near Ford’s Chicago Assembly Plant. The shuttle drivers then hauled those trailers on public roads from the storage lots to the Assembly Plant and returned the trailers to the lots; the empty racks/containers would later be picked up and transported out of state for reuse. The defendants denied overtime liability, asserting the MCA exemption because the shuttle runs were part of an overall interstate movement.

The key issue was whether these intrastate shuttle trips were “part of a continuous interstate journey” such that the Secretary of Transportation had regulatory authority over the drivers’ hours—triggering the FLSA’s MCA overtime exemption.

Summary of the Opinion

The Seventh Circuit affirmed summary judgment for the defendants. It held that the intrastate shuttle legs between Ford’s nearby storage lots and the Chicago Assembly Plant were part of a continuous interstate journey of goods originating out of state and destined for the Assembly Plant. The court likewise treated the movement of empty custom racks/containers from the Assembly Plant to the lots (for later out-of-state pickup) as part of interstate transportation. Because the MCA exemption applied, the drivers were not entitled to FLSA overtime.

The plaintiffs’ attempt to characterize the storage lots and plant collectively as a single “Ford Assembly Campus” destination failed on the stipulated record and would have created an unworkable proximity-based rule with no legal footing.

Analysis

Precedents Cited

Collins v. Heritage Wine Cellars, Ltd.

Collins v. Heritage Wine Cellars, Ltd., 589 F.3d 895 (7th Cir. 2009), provided the controlling framework. The court reiterated two core teachings from Collins:

  • An intrastate leg can be “interstate commerce” under the MCA if it remains in “practical continuity” with a larger interstate journey.
  • Temporary warehousing does not necessarily break continuity; the inquiry turns on whether the shipper had a “fixed and persisting transportation intent” beyond the storage point.

Critically, the opinion imported Collins’s four-factor test (sourced from the ICC policy statement) to decide whether the storage-lot stop was merely a “normal stop or stage” rather than the end of the interstate movement.

Burlaka v. Contract Transport Services LLC

Burlaka v. Contract Transport Services LLC, 971 F.3d 718 (7th Cir. 2020), reinforced that “continuous” does not mean uninterrupted, and that the MCA exemption may apply even when the driver’s own route is intrastate, so long as it is part of an interstate journey. The court also cited Burlaka for the policy rationale: limiting hours for safety in interstate transportation and thus displacing FLSA overtime requirements when the DOT has jurisdiction.

Walling v. Jacksonville Paper Co.

Walling v. Jacksonville Paper Co., 317 U.S. 564 (1943), supplied the classic continuity formulation: goods remain “in commerce” if the pause is a convenient intermediate step to the final destination. The Seventh Circuit used it (via Burlaka and Collins) to reject the idea that a brief storage stop necessarily ends interstate character.

ICC Policy Statement (57 Fed. Reg. 19812 (May 8, 1992))

The opinion treated the ICC Policy Statement, Motor Carrier Interstate Transportation—From Out-of-State Through Warehouses to Points in Same States, 57 Fed. Reg. 19812 (May 8, 1992), as the operative articulation of the “fixed and persisting intent” criteria. The court applied its four factors (as quoted in Collins) to Ford’s logistics model.

Regulatory Reference: 29 C.F.R. § 782.2(a)

By quoting Collins’ reference to 29 C.F.R. § 782.2(a), the opinion situated the exemption in the concept that DOT power extends to employees whose activities directly affect motor vehicle safety in interstate commerce within the MCA’s meaning.

Legal Reasoning

  1. Statutory hinge: DOT power, not the employee’s intrastate label. The court began with the FLSA’s overtime rule and the MCA exemption (29 U.S.C. § 213(b)(1)), emphasizing that the exemption turns on whether the Secretary of Transportation has authority under 49 U.S.C. § 31502 and related provisions—authority that depends on interstate transportation.
  2. Continuity analysis: “Practical continuity” and “normal stops or stages.” Relying on Burlaka, Collins, and Walling v. Jacksonville Paper Co., the court held that “continuous” interstate movement includes routine interruptions, including temporary storage, when those interruptions are part of an integrated logistics chain to a predetermined end point.
  3. Application of Collins/ICC four-factor test to Ford’s storage lots. The court found each factor satisfied:
    • Demand-based projections: Ford shipped parts based on projections/forecasts of Assembly Plant need; the quick 2–3 day turnover from lots to plant supported the factual basis for projections.
    • No processing/substantial modification: Parts were not processed, assembled, or commingled while staged.
    • Shipper control: Ford tracked trailers and directed subsequent movement from lots to plant.
    • Transportation responsibility: Ford selected, paid, and scheduled the interstate carriers; the court also treated Ford as responsible for payment in the shuttle leg context on this record.
    On these facts, the storage-lot pause resembled Collins’ “Heritage-controlled journey” where warehouse time did not break interstate character.
  4. Rejection of the “single campus destination” theory. The plaintiffs’ central counterargument was that the storage lots were effectively part of the Assembly Plant destination (like a store stockroom), making delivery to the lots the endpoint of interstate shipment. The court rejected this on multiple grounds:
    • Stipulated facts: The Assembly Plant had a specific address; the lots were separate locations “nearby,” not part of the plant.
    • Physical/geographic separation and public-road transit: The lots were non-contiguous, miles apart, and reachable only via public roads, making the shuttle movement a distinct transport leg subject to DOT safety concerns.
    • No workable legal line: A proximity-based “close enough equals destination” rule lacked legal support and would be administratively indeterminate (how near is near enough?).
    • Deposition testimony did not change the endpoint: The cited Ford testimony about “arrival” logging did not establish that Ford treated the lots as final receipt; the witness distinguished physical presence at the lots from “actual possession” upon unloading at the Assembly Plant.
  5. Empty racks/containers treated as interstate movement. The court separately confirmed that when empty custom containers left the Assembly Plant for the storage lots awaiting out-of-state pickup, their “intended destination” was the out-of-state manufacturing plants—making the shuttle leg part of interstate transportation as well.

Impact

  • Clarifies that “nearby” off-site staging lots do not become the interstate journey’s endpoint by proximity alone. The decision rejects attempts to redefine “destination” to include multiple dispersed facilities simply because they support a single industrial operation.
  • Strengthens shipper-intent and control as the focal point. For logistics models using satellite yards, drop lots, and staging facilities, the case underscores that fixed/persisting intent to move goods onward, combined with shipper control and lack of processing, will keep the movement “interstate” for MCA purposes.
  • Broader reach to reverse logistics (returnable containers). By treating the outbound movement of empty racks/containers as interstate from the start, the opinion provides additional support for applying MCA concepts to closed-loop supply chains.
  • Practical litigation consequence: summary judgment more attainable on stipulated logistics facts. Where parties can stipulate to shipping projections, control, lack of processing, and quick turnover, this opinion reinforces that the MCA exemption can be resolved as a matter of law.

Complex Concepts Simplified

FLSA overtime rule
Generally requires time-and-a-half pay for hours worked over 40 in a week (29 U.S.C. § 207(a)(1)).
MCA exemption (29 U.S.C. § 213(b)(1))
Removes FLSA overtime protection for certain drivers if the Department of Transportation has authority to regulate their qualifications and maximum hours because they are involved in transportation in interstate commerce affecting safety.
“Interstate” can include intrastate legs
A driver may never cross state lines, yet still be considered part of interstate transportation if the driver’s haul is one segment of an interstate journey of the same goods.
“Practical continuity” and “fixed and persisting intent”
Goods remain in interstate commerce through temporary stops (like warehouses or staging lots) if, when the goods were shipped, the shipper intended they would continue onward to a specific end destination and the stop is just a normal stage in getting them there.
Why processing matters
If goods are substantially transformed at the storage point, that can indicate the interstate journey ended and a new intrastate distribution cycle began. Here, the parts were not processed at the lots.

Conclusion

The Seventh Circuit held that intrastate shuttle runs between Ford-controlled storage lots and Ford’s Chicago Assembly Plant were part of a continuous interstate journey because Ford maintained a fixed and persisting intent to move out-of-state parts onward to the plant, with only a temporary staging pause and no material processing. It rejected a proximity-based “single campus” theory that would have treated dispersed lots as the shipment’s endpoint. As a result, the MCA exemption applied and the drivers were not entitled to FLSA overtime.