Court Deals DOT Another Blow in CDLIS Records Battle
Court hands DOT another defeat in battle over CDLIS records
A federal judge has issued a preliminary injunction blocking the U.S. Department of Transportation and the Department of Homeland Security from obtaining more than 17 million commercial driver’s license records held in the Commercial Driver’s License Information System.
The ruling prevents the American Association of Motor Vehicle Administrators (AAMVA), which administers and manages CDLIS, from transferring the records to DOT or other federal agencies while the lawsuit continues. It also bars DOT, the Federal Motor Carrier Safety Administration and other agencies from taking adverse action against the states involved in the case or against AAMVA because the information was not provided.
The decision is the latest development in a legal challenge brought by 21 states and the District of Columbia. The states sued after DOT demanded a broad set of CDLIS records from AAMVA.
According to the original lawsuit, DOT said the request was intended to investigate what it described as illegal practices at commercial driver’s license schools. Federal agencies also cited efforts to identify possible criminal fraud involving the issuance of CDLs to undocumented immigrants and to conduct civil immigration enforcement.
The states opposed turning over the database, pointing largely to privacy concerns involving CDL holders and applicants. The requested records cover more than 17 million drivers and applicants, making the dispute significant for professional drivers and the state agencies responsible for licensing them.
Judge finds states met the preliminary-injunction standard
Senior U.S. District Judge Anthony J. Trenga of the Eastern District of Virginia first issued a temporary restraining order in August while he considered the states’ request for a preliminary injunction. In that earlier order, Trenga noted that the legal standard for a temporary restraining order and a preliminary injunction is the same.
In granting the preliminary injunction on Sept. 17, Trenga said the federal government opposed the request on essentially the same grounds it had raised against the temporary restraining order. The agencies renewed their prior opposition and asked the court to revisit specific portions of the earlier order.
After reviewing the additional arguments, Trenga ruled that the states had made a clear showing that they were likely to succeed on the merits of their claims. He also found that the states would suffer irreparable harm without an injunction, that the balance of equities favored the states and that injunctive relief was in the public interest.
As a result, AAMVA is prohibited from transferring the requested CDLIS records to DOT or other agencies. The order will remain in effect as the case proceeds and the court considers the full scope of the dispute.
The ruling also prevents the federal agencies from penalizing AAMVA or the plaintiff states for not turning over the information. DOT had previously threatened to cancel AAMVA’s grants and had considered ending the organization’s contract to maintain CDLIS.
Illinois Attorney General Kwame Raoul, who led the coalition of states, welcomed the ruling. Raoul said the injunction prevents the administration from using federal funding as leverage to obtain sensitive personal information from millions of drivers.
He also said CDLIS is an important tool for states seeking to prevent unsafe drivers from operating commercial vehicles, and argued that the federal government’s actions threatened a system that has existed for four decades.
Separate DHS case remains on hold
The court’s order applies to the case challenging DOT’s demand. A separate lawsuit brought by 22 states and the District of Columbia challenges an identical request by the Department of Homeland Security to AAMVA.
That case is on hold while the litigation involving DOT moves forward. The outcome of the DOT case could therefore affect how the separate DHS challenge proceeds.
For drivers, the dispute centers on more than a data request. CDLIS is a national information system used by state motor vehicle agencies to track commercial licensing records. The states’ objections focus on the scope of the federal demand, the handling of personal information and the consequences of withholding federal support from AAMVA.
The injunction does not resolve the underlying legal questions. It temporarily prevents the records transfer and protects the states and AAMVA from retaliation while the court considers the merits of the case.
Ruling follows scrutiny of non-domiciled CDL rule
The decision came during the same week that FMCSA’s rule governing non-domiciled commercial driver’s licenses received close scrutiny at the U.S. Court of Appeals for the District of Columbia Circuit. The rule has also drawn legal challenges, and judges questioned the government’s position during oral arguments.
The two matters involve different legal issues, but both are part of a broader dispute over federal oversight of commercial licensing, immigration enforcement and the role of state agencies in managing CDL records.
For now, AAMVA cannot provide the more than 17 million CDLIS records sought by the federal government under the challenged request. The preliminary injunction will remain in place until the court issues further orders or reaches a final decision in the case.
