Janes v. Triborough Bridge & Tunnel Authority
Plaintiffs Riva Janes, Bruce Schwartz, Bette Goldstein, and Hillel Abraham filed a class action against the Triborough Bridge and Tunnel Authority (TBTA), Metropolitan Transportation Authority (MTA), and their chairmen. They alleged that differential toll policies on New York City bridges, which provide discounts only to residents of specific areas, violate the Commerce Clause, Privileges and Immunities Clause, and Equal Protection Clause of the U.S. Constitution, as well as New York State law. The court, relying on prior Selevan decisions, determined that the toll policies were merely minor restrictions on travel and did not warrant strict scrutiny. Applying the three-factor Northwest Airlines test, the court concluded that the tolls were a fair approximation of use, not excessive relative to the benefits conferred on the integrated transit system, and did not discriminate against interstate commerce. Ultimately, the court granted the defendants' motion for summary judgment, dismissing all federal and state law claims.