Labor & Employment Law Daily Wrap Up, WAGE-HOUR—EXEMPTIONS—7th Cir.: Shuttle truck drivers exempt from overtime requirements of FLSA because of Motor Carrier Exemption, (Apr 3, 2026)

By Ronald Miller, J.D.

The language of the FLSA and MCA makes clear that the availability of overtime wages for truck drivers can depend upon whether the routes to which they are assigned are interstate or intrastate ones.

Shuttle truck drivers who drive routes entirely within Illinois moving parts made outside the state to and from a storage lot to a Ford Assembly Plant were exempt from the overtime provisions of the FLSA because they were subject to the Motor Carrier Exemption, ruled the Seventh Circuit. The district court properly held that the routes by the shuttle truck drivers were part of an interstate shipment, because the shipments were intended to be delivered to a destination, but were diverted temporarily to a storage facility so as to allow for a timely delivery when needed at the intended destination. The parts can only be transported to the Assembly Plant from the storage lots by traveling over public roads, thus allowing the Department of Transportation to have authority over the transport (Stingley v. Laci Transport Inc., Nos. 24-1612 and 24-1613 (7th Cir. Apr. 2, 2026)).

Intrastate routes. The employees in this class action are shuttle truck drivers who drive routes entirely within Illinois, moving truckloads of automobile parts that were fabricated outside Illinois and their custom storage containers, to and from a Ford Motor Company assembly plant.

Ford assembles vehicles at its Chicago Assembly Plant. Some of the auto parts used at the plant are manufactured at Ford’s own manufacturing plants outside Illinois as well as at third-party manufacturing plants outside Illinois. Those parts are transported by interstate trucking carriers. Ford selects, contracts with, pays, and schedules those interstate truck carriers. When those parts are not in immediate need at the plant, the deliveries are directed to certain semi-trailer storage lots, which Ford owns, leases, or otherwise controls. The storage lots are at separate locations that are geographically near the plant.

Within two or three days after their arrival at the storage lots, most of the trailers containing those parts are transported to the assembly plant by the shuttle truck drivers. The drivers transport those trailers from the storage lots to the plant on public roads, and after the parts are unloaded, they transport the trailers back to the storage lots. Within two or three days, the interstate carriers then pick up the trailers from those storage lots and return them to the manufacturing plants.

Motor carrier exemption. The shuttle truck drivers alleged that the defendants failed to pay them overtime wages as is required by FLSA, 29 U.S.C. § 207(a)(1). The statute, however, exempts from its overtime provisions employees “with respect to whom the Secretary of Transportation has power to establish qualifications and maximum hours of service pursuant to the provisions of § 31502 of Title 49” of the Motor Carrier Act (MCA).

The shuttle truck drivers filed class action suits against the defendants alleging that the failure to pay them overtime wages violated the FLSA, the Illinois Minimum Wage Law, and the Chicago Minimum Wage Law. The district court granted summary judgment in favor of the defendants, and the shuttle truck drivers appealed.

Interstate versus intrastate routes. The critical question for the summary judgment motions in this case was whether the MCA excused the defendants from paying overtime wages that would otherwise be required by the FLSA to those shuttle drivers that handled the transportation from the storage lots to the assembly plant and returned the empty trailers back to the storage lots once the parts were unloaded. The language of the FLSA and MCA makes clear that the availability of overtime wages for truck drivers can depend upon whether the routes to which they are assigned are interstate or intrastate routes.

Continuous interstate journey. Even employees who drive intrastate routes, such as the shuttle drivers here, can fall under the MCA exemption because “[t]he scope of an interstate commerce run under the MCA … includes a purely intrastate run so long as it is a part of a continuous interstate journey,” [and] “[t]his continuity is not broken by routine interruptions that ‘are no more than the normal stops or stages that are common in interstate sales.’” “[I]f the halt in the movement of goods is a convenient intermediate step in the process of getting them to their final destinations, they remain ‘in commerce’ until they reach those points.”

The availability of overtime wages here turned on whether the intrastate routes are part of a continuous interstate journey. The focus is on when the goods “ceased to be in practical continuity with a larger interstate journey.”

The relevant distinction in separating intrastate from interstate transportation is whether the shipper had a fixed and persisting transportation intent beyond the terminal storage point at the time of shipment. In Collins v. Heritage Wine Cellars, Ltd., 589 F.3d 895, 897 (2009), the Seventh Circuit considered four criteria: “(1) the shipper, although it doesn’t have to have lined up its ultimate customers when the product arrives at the warehouse, ‘bases its determination of the total volume to be shipped through the warehouse on projections of customer demand that have some factual basis’; (2) ‘no processing or substantial product modification of substance occurs at the warehouse’; (3) ‘while in the warehouse, the merchandise is subject to the shipper’s control and direction as to the subsequent transportation’; and (4) ‘the shipper or consignee must bear the ultimate payment for transportation charges even if the warehouse or distribution center directly pays the transportation charges to the carrier.’ If these conditions are satisfied, the intrastate leg at the end of the shipment should be deemed part of an interstate shipment.”

Temporary diversion. Applying those criteria to the case at hand, the district court properly held that the routes by the shuttle truck drivers were part of an interstate shipment because the auto parts were intended to be delivered to the assembly plant at a time they are needed by the plant, and the temporary diversion to the storage lot did not alter the interstate nature of the shipment.

In summary, the storage lots are at locations geographically distinct from the final destination for the products, the Assembly Plant, and the parts can only be transported to the Assembly Plant from those storage lots by traveling over public roads, thus allowing the Department of Transportation to have authority over the transport.

Accordingly, the district court properly granted summary judgment in favor of the defendants.

The cases are Nos. 24-1612 and 24-1613.

Judge: Rovner, I.

Attorneys: John W. Billhorn (Billhorn Law Firm) for Renee Stingley, Earnest Smith, and Jelther Sept. George F. LaForte, Jr. (Bishop & Laforte) for Laci Transport Inc.

Companies: Laci Transport Inc.; Bosman Trucking, Inc.

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