State v. Sentinel Coach Inc. a/k/a Sentinel Limousine Inc.
A limo company hired to drive one passenger from Rhode Island to Connecticut and a different set of passengers from point A to B in Connecticut engages in intrastate commerce and must comply with Connecticut law. On May 11, 2012, the defendant's Hummer arrived at the Aqua Turf banquet facility in Plantsville, Conn., to drop off students who were celebrating their prom. Police observed that the Hummer had Rhode Island license plates and discovered that the motor vehicle was not registered to operate as a livery service in Connecticut. The Hummer had been hired to transport a woman from Westerly, Rhode Island to Rocky Hill, Conn. and then to pick up the teenagers in Rocky Hill and take them to the Aqua Turf Club. The state charged the limo company with violating Connecticut General Statutes §§14-27(d) and 13b-103(a). The defendant objected that Connecticut statutes only apply to livery service vehicles engaged in intrastate commerce within the State of Connecticut. The court found that the Hummer made one interstate trip, between Westerly, Rhode Island and Rocky Hill, Conn. and one intrastate trip, between Rocky Hill and Plantsville, Conn. The individual who traveled from Westerly, Rhode Island did not remain in the Hummer and continue on to Plantsville, Conn. There was no "continuity of movement" in the "goods" that were transported. At the time that police stopped the Hummer, it was engaged in intrastate activity, in violation of Connecticut statute. The court fined the limo company $300, plus fees and costs.