Motor Carrier Act Exemption Applies to Intrastate Shuttle Runs Between Off-Site Staging Lots and the Final Facility When the Goods Remain in a Continuous Interstate Journey

1. Introduction

In Renee Stingley v. Laci Transport Inc. (consolidated with Martaneze Johnson v. Boseman Trucking, Inc.), the Seventh Circuit addressed whether Illinois-only “shuttle” truck drivers are entitled to overtime under the Fair Labor Standards Act (FLSA) or instead fall within the Motor Carrier Act (MCA) exemption.

The plaintiffs were current and former drivers who moved trailers of automobile parts and later the empty specialized racks/containers between multiple Ford-controlled storage lots in the Chicago area and Ford’s Chicago Assembly Plant. Although the drivers’ routes were entirely intrastate, the parts originated outside Illinois and were staged briefly in nearby lots before delivery to the plant. The defendants did not pay FLSA overtime, asserting the MCA exemption.

The central issue was whether these intrastate shuttle movements were part of a “continuous interstate journey” such that the Department of Transportation (DOT) had regulatory power over the drivers’ hours—triggering the FLSA’s MCA overtime exemption.

2. Summary of the Opinion

The Seventh Circuit affirmed summary judgment for the defendants. It held that:

• The intrastate shuttle runs moving out-of-state auto parts from Ford’s staging lots to the Chicago Assembly Plant were part of a continuous interstate movement.
• The brief staging of trailers in nearby storage lots did not break the interstate character of the shipments.
• The plaintiffs’ attempt to recharacterize the plant and multiple noncontiguous lots as a single “Ford Assembly Campus” (so that delivery to a lot would end the interstate journey) was unsupported by the stipulated facts and inconsistent with governing doctrine.
• The return movement of empty racks/containers from the plant to the lots, for interstate pickup and return to out-of-state manufacturing plants, likewise remained interstate in character.

Because the drivers’ work fell within DOT’s authority under the MCA, the employees were exempt from FLSA overtime under 29 U.S.C. § 213(b)(1).

3. Analysis

3.1. Precedents Cited

Collins v. Heritage Wine Cellars, Ltd., 589 F.3d 895 (7th Cir. 2009)

Collins supplied the controlling framework. The court reiterated that a trip may be “interstate” for MCA purposes even if a particular carrier’s segment is wholly intrastate, so long as that segment is part of a broader interstate journey that remains in “practical continuity.”

Critically, Collins distinguished:

• Interstate movement continues where goods are shipped across state lines toward ultimate customers and are subject only to normal, temporary interruptions such as warehousing, without processing or repackaging that changes their substance.
• Interstate movement ends where goods arrive at their intended destination (e.g., a wholesaler’s warehouse where title passes and the wholesaler thereafter distributes on its own account), making later deliveries intrastate.

The Seventh Circuit applied Collins by analogizing Ford’s staging lots to Heritage’s temporary warehousing: a logistics pause to manage timing, not the endpoint of the shipment.

Burlaka v. Contract Transport Services LLC, 971 F.3d 718 (7th Cir. 2020)

Burlaka reinforced that “continuous interstate journey” encompasses intrastate segments when interruptions are routine stages in interstate sales, and it articulated the safety rationale underlying the MCA’s wage-and-hour structure (the MCA discourages overtime incentives for drivers subject to DOT hours regulation). The court used Burlaka to situate the case within established Seventh Circuit doctrine: the inquiry is functional and continuity-focused, not confined to state lines.

Walling v. Jacksonville Paper Co., 317 U.S. 564 (1943)

Walling provided the foundational Supreme Court statement that goods remain “in commerce” when a halt is merely “a convenient intermediate step” toward their final destinations. The Seventh Circuit relied on this principle to treat the staging-lot pause as an intermediate step rather than a terminus.

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)

Through Collins, the court again employed the ICC Policy Statement’s criteria for determining whether a shipper had a “fixed and persisting transportation intent” beyond a warehouse or storage point at the time of interstate shipment. Those criteria guided the court’s determination that Ford’s intent remained delivery to the Assembly Plant, not the lots.

3.2. Legal Reasoning

The court’s reasoning proceeds in three steps: statutory trigger, continuity doctrine, then application to Ford’s logistics model.

(a) Statutory trigger: FLSA overtime vs. MCA exemption

The FLSA generally requires overtime pay for hours over 40 per week (29 U.S.C. § 207(a)(1)), but excludes employees over whom the Secretary of Transportation has power to set qualifications and maximum hours under the MCA (29 U.S.C. § 213(b)(1); 49 U.S.C. §§ 13501(1)(A), 31502(b)), provided their work directly affects safety of operation of motor vehicles on public highways.

The dispositive question became whether the drivers’ intrastate runs were, in substance, part of “transportation ... in interstate ... commerce” within MCA meaning.

(b) Continuity doctrine: “continuous” means “practical continuity”

The court emphasized that “continuous” does not require an uninterrupted drive from origin to endpoint. The question is whether goods “ceased to be in practical continuity with a larger interstate journey.” Temporary storage does not break continuity if it is a normal stage in interstate distribution.

(c) Application: the Collins/ICC criteria demonstrate fixed, persisting intent to the Assembly Plant

Applying the four Collins factors (from the ICC Policy Statement), the court concluded the intrastate shuttle leg remained interstate:

1. Demand-based volume planning with factual basis: Ford shipped parts based on projections/forecasted need for the Assembly Plant, and the record showed most trailers were moved from lots to the plant within 2–3 days—consistent with planned, near-term consumption.
2. No processing/substantial modification at the storage point: parts were typically not processed, assembled, or commingled while staged in trailers.
3. Shipper control over goods and subsequent transportation: Ford tracked each trailer’s location and contents and directed when the trailers would be moved to the plant.
4. Shipper responsibility for transportation: the court treated Ford as responsible for the transportation arrangement/payment relevant to the journey, supporting that the staging-and-shuttle movement was part of Ford’s through-transport to the plant.

(d) Rejection of the “Ford Assembly Campus” theory

Plaintiffs argued the lots and plant should be considered one destination (like a store and its stockroom), so arrival at a lot would end interstate transit. The court rejected this on both evidentiary and doctrinal grounds:

• Stipulated facts fixed the destination: the parties stipulated a specific address for the Assembly Plant and described the lots as separate locations “nearby.”
• Geographic noncontiguity matters functionally: the lots were separated by miles, reachable only via public roads, and not uniformly owned by Ford. The need to drive over public highways between lots and plant underscores DOT’s safety jurisdiction.
• No workable legal standard for “close enough”: the court noted the lack of support for a rule that proximity alone converts a warehouse/staging area into the shipment’s destination; adopting such a rule would create line-drawing problems (e.g., 5 miles vs. 100 miles).
• Deposition testimony did not change the analysis: testimony that Ford recorded “arrival” at lots did not mean Ford took “actual possession” there; the record suggested possession/responsibility remained with the carrier until unloading at the plant.

(e) Empty racks/containers: outbound interstate intent is even clearer

The court separately confirmed that the post-unloading movement of empty custom racks/containers from the plant to the lots, followed by interstate pickup to out-of-state manufacturing plants, is likewise interstate from inception: the intended destination upon departure from the plant is out of state.

3.3. Impact

• Clarifies “staging lot” cases in industrial supply chains: In modern just-in-time manufacturing, shippers frequently use off-site trailer yards to manage congestion and timing. This decision treats those yards like temporary warehouses under Collins, preserving interstate character when the shipper’s intent and control show the yard is not the endpoint.
• Constrains “single campus” reframing: Employers and employees litigating MCA exemption disputes can expect courts to look past labels (“campus”) and ask whether the interim location is functionally a waypoint requiring further directed transport to a distinct final facility.
• Expands predictability for intrastate drayage/shuttle operations: Carriers whose drivers only move goods within one state may still fall under the MCA exemption when they operate a leg of an interstate movement governed by a shipper’s fixed and persisting intent.
• Practical litigation effect: Where parties stipulate key logistics facts (destination address; “nearby” lots; lack of processing; shipper tracking/control), plaintiffs may face an uphill battle avoiding the MCA exemption at summary judgment.

4. Complex Concepts Simplified

FLSA overtime rule

Federal law generally requiring time-and-a-half pay for hours worked over 40 in a week.

Motor Carrier Act (MCA) exemption (29 U.S.C. § 213(b)(1))

An exception to FLSA overtime for certain transportation workers when the DOT has authority to regulate their hours for safety reasons. If the exemption applies, the employer need not pay FLSA overtime.

“Continuous interstate journey” / “practical continuity”

A shipment can remain interstate even with pauses (like temporary storage) and even if one leg is driven wholly within one state. The key is whether the pause is just a normal step on the way to an out-of-state-planned destination rather than the point where the shipment truly ends.

Fixed and persisting transportation intent

Whether, at the time goods cross state lines, the shipper already intends the goods to move beyond the temporary storage point to a specific type of endpoint (often supported by forecasts, control over goods, lack of processing, and responsibility for transportation).

Why “no processing” matters

If goods are substantially altered at the in-state facility, that can indicate the interstate trip ended and a new, separate intrastate distribution began. If goods merely wait there unchanged, continuity is more likely.

5. Conclusion

The Seventh Circuit held that intrastate shuttle drivers moving trailers between Ford-controlled staging lots and Ford’s Chicago Assembly Plant fell within the MCA exemption because their routes were part of a continuous interstate journey. Relying heavily on Collins v. Heritage Wine Cellars, Ltd. and the ICC’s “fixed and persisting intent” criteria, the court treated temporary staging in nearby lots as a routine interruption that does not end interstate commerce. The decision reinforces a functional, logistics-driven approach: when goods remain under shipper control, are not processed, and are staged only to time delivery to a final facility, the last intrastate miles can remain “interstate” for MCA/FLSA purposes—foreclosing FLSA overtime.