Owner-Operator Independent Drivers Ass'n v. United States Department of Transportation
879 F.3d 339
| D.C. Cir. | 2018Background
- FMCSA maintains the Motor Carrier Management Information System (MCMIS) with driver crash and inspection records and operates a Pre‑Employment Screening Program (PSP) that shares certain records with prospective employers.
- Federal law requires states to report accurate safety data and requires the Department to ensure the data’s accuracy and provide a correction procedure (DataQs) through which drivers can challenge records.
- Five commercial drivers and their industry association sued the Department alleging it failed to ensure accuracy of MCMIS, sought injunctive/declaratory relief under the APA and damages under the FCRA; two drivers’ records (Mowrer and Weaver) had been disseminated to prospective employers; the others’ records were not disseminated.
- The district court granted summary judgment for the Department for lack of Article III standing; the drivers appealed alleging concrete injury from inaccurate records remaining in the database.
- The D.C. Circuit applied Spokeo’s requirement that statutory violations produce a concrete (de facto) injury and held that mere existence of inaccurate records in the database, without dissemination or imminent dissemination, is not a concrete injury; but dissemination to third parties is concrete and supports damages claims for Mowrer and Weaver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Department’s failure to ensure accuracy of MCMIS records alone confers Article III standing | Drivers: statutory procedural violation (right to accurate records) itself is a concrete injury; no additional harm required | DOT: mere statutory noncompliance without concrete, de facto harm is insufficient under Spokeo | Mere existence of inaccurate records, without publication or imminent dissemination, is not a concrete injury; no standing for most plaintiffs |
| Whether dissemination of inaccurate records to third parties confers standing for damages | Drivers: dissemination of false safety reports harms reputation and employment prospects | DOT: generally disputed but conceded at argument that dissemination would suffice | Dissemination to prospective employers (as to Mowrer and Weaver) is sufficiently concrete to support damages claims |
| Whether plaintiffs have standing for prospective (injunctive/declaratory) relief | Drivers/Association: ongoing risk from database inaccuracies warrants prospective relief | DOT: records have aged out or rule changes eliminated imminent dissemination risk | No standing for prospective relief—dissemination is not imminent; rule changes and time limitations removed risk |
| Whether Congress intended to create a private right of action solely by recognizing accuracy obligations in statute | Drivers: statutory scheme and Spokeo’s ‘‘no additional harm’’ language permit standing on statutory injury alone | DOT: statutory provisions focus on preventing dissemination, not creating private causes of action for mere inaccuracy | Court: statutes and history indicate Congress targeted dissemination; no clear creation of a private injury based solely on record inaccuracy |
Key Cases Cited
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (Article III requires a concrete and particularized injury; a statutory violation alone may not suffice)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact that is concrete, particularized, and actual or imminent)
- Hancock v. Urban Outfitters, Inc., 830 F.3d 511 (D.C. Cir. 2016) (post‑Spokeo application: mere procedural violation without concrete harm insufficient)
- Friends of Animals v. Jewell, 828 F.3d 989 (D.C. Cir. 2016) (informational‑standing requires deprivation of statutory disclosure and the type of harm Congress sought to prevent)
- Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982) (statutory creation of legal rights can give rise to standing when invasion of those rights is alleged)
- Town of Chester v. Laroe Estates, Inc., 137 S. Ct. 1645 (2017) (standing not dispensed in gross; must show standing for each form of relief)
- Friends of the Earth, Inc. v. Laidlaw Environmental Servs., 528 U.S. 167 (2000) (plaintiff must demonstrate standing separately for prospective relief)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (plaintiff must show actual or imminent injury to seek prospective relief)
- Attias v. CareFirst, Inc., 865 F.3d 620 (D.C. Cir. 2017) (data‑breach case recognizing substantial risk of identity theft can constitute concrete injury)