Regulation Watch2 min read

SBTC presses court to strip New York, California CDL authority

SBTC asked the D.C. Circuit to force FMCSA to decertify New York and California, but experts say the bid faces long odds.

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The Small Business in Transportation Coalition has sharpened its case asking the Federal Motor Carrier Safety Administration to decertify the CDL programs of New York and California.

In filings submitted July 10 to the U.S. Court of Appeals for the District of Columbia Circuit, SBTC argued that federal law requires the U.S. Department of Transportation to decertify any state found in substantial noncompliance with federal CDL rules and asked the court to compel the agency to act. The coalition also asked the court to immediately suspend both states’ CDL authority until they are found to be in substantial compliance with federal law.

SBTC said one issue for the court is whether 49 U.S.C. §31312 makes decertification mandatory once the transportation secretary determines a state is in substantial noncompliance. The group also argued DOT unlawfully delayed acting on its May 27, 2025, petition seeking decertification orders against New York and California.

The filings mark the next procedural step after the court docketed the case last month. In additional filings submitted July 10, SBTC said it wants the D.C. Circuit to decide whether Transportation Secretary Sean Duffy has a mandatory duty to decertify the two states after FMCSA’s findings.

The coalition identified FMCSA’s April 16 notice finding New York substantially noncompliant as one of the agency actions it is challenging. California’s Department of Motor Vehicles declined to comment on the litigation, calling it “a federal matter.” FMCSA, the New York Department of Motor Vehicles and SBTC did not respond to requests for comment.

Transportation attorney Greg Reed of Hanson Bridgett LLP said the case is unusual because FMCSA has never taken the step of decertifying a state’s CDL program. He said DOT has multiple enforcement tools and broad discretion over how it handles CDL compliance, including withholding federal highway funds while states work toward compliance.

Key dates

SBTC petition to decertify New York and California

What it means

Drivers

CVSA said a decertification order would mainly affect future CDL issuance, renewals, transfers and upgrades, not automatically invalidate every existing CDL.

Fleets

If a state were decertified, CVSA said the biggest disruption would be to future drivers and CDL transactions, which could affect how states add new drivers.

Safety pros

CVSA said roadside inspectors verify CDL status through CDLIS or Nlets and would need FMCSA guidance if a state were ever decertified.

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