## Facts

- Congress enacted the Motor Carrier Act of 1935, authorizing the Interstate Commerce Commission (ICC) to establish reasonable requirements for “qualifications and maximum hours of service of employees” and for “safety of operation and equipment” of interstate motor carriers.
- The ICC interpreted “employees” in § 204(a) to mean only employees whose work affects safety of operation (e.g., drivers and certain maintenance and loading personnel), and declined to regulate hours and qualifications for clerical and other non-safety employees.
- American Trucking Associations and several carriers sued to compel the ICC to assert jurisdiction over all motor-carrier employees for hours-and-qualifications regulation.
- The dispute had practical significance because the Fair Labor Standards Act exempted from its wage-and-overtime rules those employees over whom the ICC had power to set qualifications and maximum hours.
- A three-judge federal district court ordered the ICC to set aside its narrower position and to take jurisdiction and proceed to determine qualifications and maximum hours for all employees of regulated carriers.
- The United States and the ICC appealed directly to the Supreme Court.

## Issues

1. Whether § 204(a) of the Motor Carrier Act authorizes the ICC to regulate qualifications and maximum hours of service for all motor-carrier employees or only those whose duties affect safety of operation.
2. Whether statutory interpretation may depart from a broad literal reading of “employees” when context, legislative purpose, and administrative construction indicate a narrower meaning.

## Decision

- The Supreme Court reversed the district court.
- The Court held that the ICC’s § 204(a) authority over “qualifications and maximum hours of service of employees” is confined to employees whose duties affect safety of operation.
- The Court rejected an interpretation that would require the ICC to regulate large numbers of employees whose duties do not affect safety.
- The Court gave substantial weight to the consistent, contemporaneous interpretations of § 204(a) by the ICC and the Department of Labor’s Wage and Hour Division.
- A dissent would have read “employees” to cover all employees based on the statute’s unqualified text.

## Legal Principles

- Under the Motor Carrier Act, ICC power to prescribe employee qualifications and maximum hours extends only to employees whose activities affect motor-carrier safety of operation.
- Courts may look beyond a superficially broad statutory phrase where a literal reading would produce results plainly inconsistent with the statute’s policy and structure.
- Legislative history, statutory context, and consistent administrative construction are legitimate interpretive aids, including where statutory terms appear clear when read in isolation.
- Statutory provisions should be construed to fit the regulatory purpose assigned to the agency (here, transportation safety rather than general labor regulation).

## Conclusion

The Court limited the ICC’s hours-and-qualifications jurisdiction to safety-affecting motor-carrier employees, rejecting a reading that would have extended ICC regulation to all carrier employees and correspondingly broadened the wage-and-overtime exemption tied to ICC authority.


United States v. Am. Trucking Ass'ns, Inc., 310 U.S. 534 (1940)