American Bus Association, Inc. v. District of Columbia

Summary

The District of Columbia Court of Appeals reviewed a challenge to District requirements that charter buses obtain District registration, apportioned registration under the International Registration Plan, or a six-day trip permit. The court held that the Associations had not shown that the statutory scheme violated the dormant Commerce Clause or conflicted with the International Registration Plan, and affirmed summary judgment for the District. The court proceeded to the merits without definitively resolving whether the challenged charges were taxes subject to the District's Anti-Injunction Act.

Holdings

1. The scheme did not violate the dormant Commerce Clause because it applied evenhandedly to in-state and out-of-state charter-bus operators, did not discriminate against interstate commerce, and the record did not show that its incidental burdens were clearly excessive in relation to the District's legitimate interests in regulating roadway and infrastructure impacts.
2. The scheme did not conflict with the International Registration Plan because the IRP did not prohibit the District from requiring charter buses to choose between apportioned registration and other forms of registration or fee payment.
3. The court did not definitively resolve whether the challenged charges were taxes or fees because the merits clearly disposed of the appeal; rejection of the substantive claims also defeated the statutory exception requiring that the government could under no circumstances prevail.

Questions Presented

1. Whether the District's charter-bus registration and trip-permit scheme discriminated against or unduly burdened interstate commerce in violation of the dormant Commerce Clause.
2. Whether the District's requirement that charter buses choose among District registration, apportioned registration, or a trip permit conflicted with the International Registration Plan, which permits charter buses to elect apportioned registration.
3. Whether the Superior Court lacked jurisdiction under the District's tax-assessment procedures or whether the action was barred by the District of Columbia Anti-Injunction Act.

Disposition

affirmed