Matt Lawson v. Michael Huerta
692 F. App'x 790
6th Cir.2017Background
- Matt Lawson, owner of Lawson Aviation, performed alterations and an annual inspection on a Cessna that required FAA field approval and Form 337 filings.
- Inspector Moore approved a Form 337 allowing a G-model engine and a 78-inch propeller (instead of the STC’s 76-inch), and Lawson certified completion on two Form 337s and in the aircraft logbook.
- A later inspection by other mechanics and FAA Inspector Steffes found 21 discrepancies between the Aircraft’s condition and its records (engine model, propeller length, rivet material, and airworthiness entries).
- The FAA concluded Lawson intentionally falsified maintenance records and issued an emergency revocation of his Aircraft Mechanic Certificate and Inspection Authorization.
- The NTSB (after an ALJ hearing) affirmed the FAA’s finding of intentional falsification and the revocation; Lawson petitioned for judicial review in the Sixth Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NTSB factual findings were supported by substantial evidence | Lawson: Board lacked direct evidence; findings rest on circumstantial gaps and ambiguous entries | FAA/NTSB: Circumstantial evidence (photos, inspector testimony, admissions, short post-repair flight time) supports intentional falsification | Held: Substantial evidence supports findings of intentional falsification for false airworthiness entries, wrong engine/propeller, and rivet material |
| Pleading adequacy (fraud-type allegations; Rules 8 & 9) | Lawson: FAA complaint should meet Rule 9(b) and provide heightened particularity; alternatively Rule 8 insufficient | FAA: Administrative notice-pleading under Rule 8 is adequate; Rule 9(b) objection waived because not raised below | Held: Rule 9(b) argument waived; complaint satisfied Rule 8 notice pleading |
| Application of the stale-complaint rule (49 C.F.R. §821.33) | Lawson: Charges were stale; should have been dismissed because older than six months | FAA: Rule inapplicable where complaint alleges lack of qualification (intentional falsification) and Lawson failed to timely move to dismiss | Held: Argument untimely and, on the merits, complaint alleges lack of qualification so stale-complaint rule does not bar the action |
| Appropriateness of revocation as sanction | Lawson: Even if violations occurred, revocation is excessive | FAA/NTSB: Intentional falsification undermines integrity of safety records; even a single intentional falsification warrants revocation | Held: Revocation not arbitrary or capricious; consistent precedent supports revocation for intentional falsification |
Key Cases Cited
- Blackman v. Busey, 938 F.2d 659 (6th Cir. 1991) (standard of review for NTSB orders; factual findings upheld if supported by substantial evidence)
- Kratt v. Garvey, 342 F.3d 475 (6th Cir. 2003) (substantial-evidence standard explained)
- Cassis v. Helms, 737 F.2d 545 (6th Cir. 1984) (intentional falsification defined as knowing misrepresentation of a material fact)
- Hart v. McLucas, 535 F.2d 516 (9th Cir. 1976) (elements for intentional falsification)
- Cooper v. NTSB, 660 F.3d 476 (D.C. Cir. 2011) (an airman may be held to have intended submissions to be relied upon when acting with willful disregard for their truth)
- Olsen v. NTSB, 14 F.3d 471 (9th Cir. 1994) (single intentional falsification can justify revocation of mechanic certificate)
- Mayer v. Mylod, 988 F.2d 635 (6th Cir. 1993) (Rule 8 functions to give notice so parties can defend claims)