OOIDA v. Department of Transportation

In the United States, an individual operating a commercial vehicle is required to have a commercial driver’s license and receive a medical certification verifying that the operator’s physical condition allows the operator to operate a commercial vehicle safely. In 2005, Congress adopted the Safe, Accountable, Flexible, Efficient Transportation Equity Act (the statute), which required all commercial-vehicle operators to obtain the necessary medical certification from a national registry of medical examiners established by the secretary of transportation. The Federal Motor Carrier Safety Administration (FMCSA), a federal administrative agency that is part of the Department of Transportation (defendant), later proposed an administrative rule to implement the national registry of medical examiners. Under the proposed rule, Mexican and Canadian drivers operating in the US would be exempt from the national-registry requirement. Instead, Mexican and Canadian drivers would be governed by existing executive agreements between the US and Mexico and the US and Canada, respectively. Under these agreements, each of the countries recognized the driver’s licenses issued by the other countries. In Mexico and Canada, a physical-fitness determination is required to obtain a commercial driver’s license. Therefore, the US government treats a Mexican or Canadian commercial license as proof of medical fitness. The Owner-Operator Independent Drivers Association (OOIDA) (plaintiff), a trade association, challenged the decision of the FMCSA to exempt Mexican and Canadian drivers operating commercial vehicles in the US from the national-registry requirement in federal court. The FMCSA argued that the exemption was required by the executive agreements with Mexico and Canada. OOIDA contended that the exemption is incompatible with the text of the statute.