D.C. Circuit Concludes Trailers Are Not “Motor Vehicles”
Law students are often asked to consider what constitutes a “vehicle,” as in what sorts of things are covered by a law prohibiting “Vehicles in the Park.” Today, the U.S. Court of Appeals for the D.C. Circuit resolved a somewhat similar question in reviewing a recent Environmental Protection Agency regulation.
In Truck Trailer Manufacturer Association v. Environmental Protection Agency, a partially divided panel considered whether trailers can be regulated as “motor vehicles” under federal law. In the view of the court, the tractors pulling trailers may constitute vehicles, but the trailers themselves are not.
Judge Walker wrote the opinion for the court, joined by Judge Katsas. His opinion begins:
In 2016, the Environmental Protection Agency issued a rule for trailers pulled by tractors based on a statute enabling the EPA to regulate “motor vehicles.” In that same rule, the National Highway Traffic Safety Administration issued fuel efficiency standards for trailers based on a statute enabling NHTSA to regulate “commercial medium-duty or heavy-duty on-highway vehicles.”
Trailers, however, have no motor. They are therefore not “motor vehicles.” Nor are they “vehicles” when that term is used in the context of a vehicle’s fuel eco
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