American Trucking Associations, Inc. v. New York State Thruway Authority (Second Circuit)

On behalf of the American Trucking Associations and several trucking companies, we filed a class action against the New York State Thruway Authority and some of its officials. The suit alleges that the Thruway Authority has been violating the Commerce Clause by charging excessive truck tolls and spending the extra revenue not on roads and bridges but principally on the New York State Canal System—waterways and adjacent trails and facilities that are used predominantly for recreational purposes. The district court dismissed the suit for failure to join the State of New York as a defendant. According to the district court, the State was a necessary party because it has a duty to fund the canals, but it could not be joined as a party to a suit in federal court because it enjoys sovereign immunity under the Eleventh Amendment. We appealed to the Second Circuit, which held that the district court’s decision is irreconcilable with Federal Rule of Civil Procedure 19 and circuit precedent holding that the Thruway Authority is an independent entity.