Current and former shuttle truck drivers transported automobile parts and custom storage containers between Ford Motor Company storage lots and its Chicago Assembly Plant, driving routes entirely within Illinois. The drivers filed class actions against Laci Transport Inc., Bosman Trucking Inc. and other defendants, alleging violations of the Fair Labor Standards Act, Illinois Minimum Wage Law and Chicago Minimum Wage Law for failure to pay overtime wages. The auto parts were manufactured outside Illinois and temporarily stored at various lots around Chicago before being transported to the assembly plant within two to three days.
Circuit Judge Ilana Rovner wrote that the drivers' routes qualified for the Motor Carrier Act exemption because they remained part of a "continuous interstate journey" even though the actual driving occurred only within Illinois. "The original and persisting intended destination for the shipment was always the Assembly Plant, not the storage lot, and only parts not immediately needed by the Assembly Plant were held temporarily in the storage lots," Rovner explained. The court applied a four-part test from Collins v. Heritage Wine Cellars, finding Ford controlled the parts during storage, based shipping volumes on demand projections, performed no processing at storage facilities, and bore ultimate transportation costs.
The Northern District of Illinois granted summary judgment for the defendants in the consolidated cases, leading to the drivers' appeal. The plaintiffs argued unsuccessfully that the storage lots and assembly plant should be considered one "Ford Assembly Campus," making their routes purely intrastate deliveries within a single destination.
The decision reinforces the broad scope of interstate commerce exemptions under the Motor Carrier Act, potentially affecting overtime claims by drivers in similar supply chain arrangements. The ruling clarifies that temporary storage facilities near final destinations don't break the continuity of interstate shipments when the shipper maintains control and intent for further transportation.