Owner-Operator Independent Drivers Ass'n v. United States Department of Transportation, 831 F.3d 961

FMCSA maintains a Carrier Safety Measurement System that ranks carriers by Crash Indicator within safety-event groups (combo vs. straight trucks) based on accidents per vehicle over 24 months. Carriers with rankings ≥65 may face enforcement interventions.
FMCSA issued regulatory guidance (Mar. 2015) stating crashes involving attenuator trucks deployed in work zones are not counted as "accidents" and may be removed from carriers' crash records, effective May 26, 2015.
Petitioners: Owner-Operator Independent Drivers Association (trade association) and member Kuehl Trucking challenged the guidance, arguing FMCSA issued a legislative rule without notice-and-comment (APA) and that the rule was arbitrary and capricious.
Petitioners asserted competitive injury: attenuator-truck carriers would benefit in Crash Indicator rankings (a zero-sum percentile), harming non-attenuator carriers like Kuehl by lowering their relative ranking and raising risk of intervention.
The government argued plaintiffs lacked Article III standing and that the guidance was interpretive (or otherwise lawful).
The Eighth Circuit dismissed the petition for lack of Article III standing because petitioners failed to show a concrete, particularized injury traceable to the guidance (no evidence attenuator carriers in Kuehl's safety-event group benefited; supplemental declarations did not show members had qualifying recent accidents).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Article III standing to challenge FMCSA guidance	Kuehl and OOIDA suffer competitive injury: attenuator carriers' removed accidents will improve their percentile rankings, harming Kuehl's ranking and increasing enforcement risk	No concrete injury shown: petitioners offered no evidence any attenuator carriers in Kuehl's safety-event group benefited; petitioners must prove standing with specific facts	Dismissed for lack of standing; petitioners did not show injury-in-fact traceable to the guidance
Whether guidance required notice-and-comment under APA	Guidance is a legislative rule altering substantive rights and thus required notice-and-comment	Guidance is interpretive (exempt from notice-and-comment) and/or not arbitrary and capricious	Court did not reach merits after resolving standing; merits not decided

Allen v. Wright, 468 U.S. 737 (standing requires a case or controversy)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (injury-in-fact must be concrete and particularized)
Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (standing requires that injury be redressable and traceable)
Hunt v. Wash. State Apple Advertising Comm'n, 432 U.S. 333 (associational standing requirements)
FW/PBS, Inc. v. City of Dallas, 493 U.S. 215 (standing must affirmatively appear in the record)
Clapper v. Amnesty Int'l USA, 133 S. Ct. 1138 (burden to prove standing with specific evidence)
Davis v. FEC, 554 U.S. 724 (standing assessed at the time suit is filed)