Lucas v. Federal Motor Carrier Safety Administration

CourtDistrict Court, D. Maryland
DecidedMay 13, 2025
Docket1:24-cv-03004
StatusUnknown

This text of Lucas v. Federal Motor Carrier Safety Administration (Lucas v. Federal Motor Carrier Safety Administration) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lucas v. Federal Motor Carrier Safety Administration, (D. Md. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

SIGNOR LUCAS, JR., *

Plaintiff, *

v. * Civil Action No. EA-24-3004

FEDERAL MOTOR CARRIER SAFETY * ADMINISTRATION, * Defendant. *

MEMORANDUM OPINION

Plaintiff Signor Lucas, Jr., initiated the above-captioned action on October 16, 2024, against Defendant Federal Motor Carrier Safety Administration (FMCSA) alleging defamation, slander, and a violation of the Fifth Amendment to the United States Constitution, U.S. Const. amend V, and seeking $400,000 in damages. ECF No. 1. Pending before the Court is the FMCSA’s motion to dismiss (ECF No. 18), which is fully briefed (ECF Nos. 21–22).1 No hearing is necessary. Local Rule 105.6 (D. Md. 2023). For the reasons set forth below, the motion is granted. I. BACKGROUND Mr. Lucas’s claims arise from allegedly false information regarding Mr. Lucas’s driving record that is contained in a report prepared by the FMCSA. A. Relevant Statutory Framework Congress established the FMCSA as an administration of the United States Department of Transportation through enactment of the Motor Carrier Safety Improvement Act of 1999, Pub. L.

1 Mr. Lucas attempted to file two additional responses to the pending motion, one of which was returned. ECF Nos. 23–24. The Court has not considered either filing in rendering a decision on this motion, as they are unapproved surreplies. Local Rule 105.2(a) (D. Md. 2023) (“Unless otherwise ordered by the Court, surreply memoranda are not permitted to be filed.”). No. 106-159, 86 Stat. 1249-1250. 49 U.S.C. § 113(a). The FMCSA has statutorily defined duties designed to further “the highest degree of safety in motor carrier transportation.” 49 U.S.C. § 113(b); see also Privacy Act of 1974; Department of Transportation, Federal Motor Carrier Safety Administration (FMCSA) 007 Pre-Employment Screening Program (PSP System of Records Notice), 77 Fed. Reg. 42,548, 42,549 (July 19, 2012) (“The FMCSA’s primary mission is to prevent commercial motor vehicle-related fatalities and injuries.”). “To fulfill [this] mandate . . . the [FMCSA] . . . maintains the Motor Carrier Management

Information System [(MCMIS)], a database of commercial truck drivers’ safety records.” Owner-Operator Indep. Drivers Ass’n, Inc. v. United States Dep’t of Transportation, 879 F.3d 339, 340-341 (D.C. Cir. 2018) (citing 49 U.S.C. § 113). “The MCMIS contains a wide range of information on commercial drivers, including crash reports and records of roadside inspections.” Mowrer v. United States Dep’t of Transportation, 14 F.4th 723, 726 (D.C. Cir. 2021); see also Privacy Act of 1974; Department of Transportation, Federal Motor Carrier Safety Administration; DOT/FMCSA 001Motor Carrier Management Information System (MCMIS) System of Records (MCMIS System of Records Update), 78 Fed. Reg. 59,082-01, 59,083 (Sept. 25, 2013) (identifying the categories of records within MCMIS). Crash data in MCMIS are “collected from state and local police crash reports.” MCMIS System of Records Update,

78 Fed. Reg. at 59,083. Driver and vehicle safety violations and inspection data are collected “during roadside inspections of drivers and vehicles.” Id. In 2005, Congress enacted the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (the SAFETEA-LU Act), Pub. L. No. 109-59, Sec. 4117, 119 Stat. 1144, 1728-1729, which, among other things, directs the FMCSA to provide electronic access to reports regarding accidents, inspections, and serious driver-related safety violations to motor carrier industry pre-employment screeners. Mowrer, 14 F.4th at 726; 49 U.S.C. § 31150(a). The FMSCA “implemented this direction by creating the Pre-Employment Screening Program (PSP),” Mowrer, 14 F.4th at 726-727, “which provides employers with reports containing crash data from the previous five years and inspection data from the previous three,” Owner-Operator Indep. Drivers Ass’n, Inc., 879 F.3d at 341; see also PSP System of Records Notice, 77 Fed. Reg. at 42,549. According to the FMCSA, “making this driver data available to potential employers and [drivers] will improve the quality of safety data and help employers make more informed decisions when hiring commercial drivers.” PSP System of

Records Notice, 77 Fed. Reg. at 42,549. The SAFETEA-LU Act further directs the FMCSA to “provide a procedure for [drivers] to correct inaccurate information.” 49 U.S.C.A. § 31150(b)(4). In fulfillment of this mandate, the FMSCA “created a system called DataQs, which allows drivers to challenge information in their PSP reports,” Mowrer, 14 F.4th at 727, including “crashes, inspections, registration, operating authority, safety audits and enforcement actions,” PSP System of Records Notice, 77 Fed. Reg. at 42,551. “DataQs forwards challenges to the state that submitted the contested information, and the state then decides whether to modify or remove it.” Mowrer, 14 F.4th at 727 (emphasis added). The FMCSA “is not authorized to direct a State to change or alter MCMIS data for violations or inspections originating within a particular State.” PSP System of

Records Notice, 77 Fed. Reg. at 42,551. The FMCSA considers a State’s “determination on the validity of a challenge” to be “the final resolution of the challenge.” Id. The FMCSA “cannot change State records without State consent.” Id. B. Factual Background2 Mr. Lucas is a truck driver with 35 years of experience who alleges he has not been able to find employment as a commercial driver because of the “defaming and slanderous statements on [ ]his PSP report.” ECF Nos. 1 at 6; 21 at 3.3 Specifically, Mr. Lucas alleges that “[f]or nearly two years” he “can not find work any where because of this PSP report.” ECF No. 1 at 6. The PSP report Mr. Lucas filed with the Court reflects that Mr. Lucas was not involved in any crashes and was subject to four driver inspections, one driver out-of-service inspection, and

two vehicle inspections. ECF 4-1 at 1. The PSP report lists four roadside inspections occurring in Indiana, Utah, Florida, and Georgia, with several reported driver-vehicle violations. Id. at 1-2. Mr. Lucas alleges that one of the safety violations reported in Florida on August 23, 2022, and all

2 This factual summary is drawn from the allegations in the Complaint (ECF No. 1), which are accepted as true for the purposes of deciding this motion, as well as documents that are integral to the Complaint and authentic. Goines v. Valley Cmty. Servs. Bd., 822 F.3d 159, 164 (4th Cir. 2016); E.I. du Pont de Nemours & Co. v. Kolon Indus., Inc., 637 F.3d 435, 440 (4th Cir. 2011). The Court has included in this factual summary reference to Mr. Lucas’s Pre- Employment Screening Program (PSP) report (ECF No. 4-1) because the information in this report gives rise to Mr. Lucas’s asserted claims and the FMCSA does not contest its authenticity. ECF Nos. 1 at 6; 18-1 at 4.

The Court has also included in this summary additional factual allegations that Mr. Lucas included in his opposition to the pending motion to dismiss. ECF No. 21. Typically, a “plaintiff ‘is bound by the allegations contained in [the] complaint and cannot, through the use of motion briefs, amend the complaint.’” McDonald v. LG Elecs. USA, Inc., 219 F. Supp. 3d 533, 541 (D. Md. 2016) (quoting Zachair, Ltd. v. Driggs, 965 F. Supp. 741, 748 (D. Md. 1997), aff’d, 141 F.3d 1162 (4th Cir. 1998)).

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