## Facts

- Federal law requires commercial motor vehicle operators to hold a commercial driver’s license (CDL) and medical certification of physical qualification.
- Congress directed the Department of Transportation (through FMCSA) to create a national registry of certified medical examiners and to require medical examiner’s certificates from registry-listed examiners.
- FMCSA issued a final rule implementing the registry requirement but exempted properly licensed Canadian and Mexican drivers operating in the United States.
- FMCSA relied on existing reciprocal cross-border arrangements under which the United States recognizes Canadian and Mexican CDLs and treats them as evidence that the driver satisfied medical-fitness requirements in the licensing country.
- A trade association representing U.S. independent drivers and small trucking businesses challenged the exemption as contrary to the statute and inconsistent with safety goals.

## Issues

1. Whether the statute unambiguously required all commercial drivers operating in the United States, including Canadian- and Mexican-licensed drivers, to obtain medical certification from a U.S. national-registry-listed medical examiner.
2. If the statute was ambiguous, whether FMCSA reasonably interpreted it to allow reliance on Canadian and Mexican licensing/medical-fitness determinations in lieu of U.S. registry-based certification.
3. Whether the exemption was arbitrary or capricious under the Administrative Procedure Act.

## Decision

- The court denied the petition for review and upheld the challenged portion of the final rule.
- The court found the statute did not clearly resolve how the national registry requirement applied to foreign-licensed drivers operating under reciprocal arrangements.
- Applying Chevron, the court held FMCSA’s exemption was a reasonable construction of the statute.
- The court also held the agency provided a reasoned explanation and the rule was not arbitrary or capricious.

## Legal Principles

- When a statute is silent or ambiguous on a specific application question, a reviewing court applies Chevron and defers to a reasonable agency interpretation.
- An agency may interpret a transportation safety statute in a manner that accommodates existing international reciprocal licensing arrangements when Congress has not clearly displaced those arrangements.
- Under the APA, an agency rule is sustained when the agency explains its decision in a reasoned manner and the outcome is not arbitrary or capricious, including where the agency reasonably determines that alternative regulatory mechanisms address the statute’s safety objective.

## Conclusion

The D.C. Circuit upheld FMCSA’s decision to exempt Canadian- and Mexican-licensed commercial drivers from the U.S. national registry medical examiner requirement, concluding the statute did not clearly require universal application and that the agency’s harmonizing interpretation—supported by reciprocal licensing arrangements and foreign medical-fitness requirements—was reasonable and adequately explained.


Owner-Operator Indep. Drivers Ass’n, Inc. v. U.S. Dep’t of Transp., 724 F.3d 230 (D.C. Cir. 2013)