Morales v. Federal Aviation Administration Aerospace Medical Certificate Division Manager David M. O'Brien

CourtDistrict Court, D. Nevada
DecidedJanuary 10, 2024
Docket2:23-cv-01455
StatusUnknown

This text of Morales v. Federal Aviation Administration Aerospace Medical Certificate Division Manager David M. O'Brien (Morales v. Federal Aviation Administration Aerospace Medical Certificate Division Manager David M. O'Brien) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morales v. Federal Aviation Administration Aerospace Medical Certificate Division Manager David M. O'Brien, (D. Nev. 2024).

Opinion

1 2 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 4 Dominic Morales, Case No. 2:23-cv-01455-CDS-MDC

5 Plaintiff Order Granting Defendant’s 6 v. Motion to Dismiss and Closing Case

7 Federal Aviation Administration Aerospace Medical Certificate Division Manager David [ECF No. 7] 8 M. Obrien,

9 Defendant 10 11 In September of 2023, pro se plaintiff Dominic Morales initiated this action against 12 defendant David M. Obrien, the Federal Aviation Administration (FAA) aerospace medicine 13 certificate division manager, for the denial of his airman medical certificate. See ECF No. 1-2. 14 Morales seeks redress of this denial, claiming that he is entitled to an airman medical certificate. 15 Id. In October of 2023, defendant filed a motion to dismiss, arguing that this court lacks subject 16 matter jurisdiction due to Morales’ failure to exhaust his administrative remedies. ECF No. 7. 17 Morales opposes the motion. ECF No. 8. For the reasons herein, the court finds that it lacks 18 subject-matter jurisdiction and grants defendant’s motion to dismiss. 19 I. Background 20 On March 21, 2022, Morales applied for a first-class airman medical certificate to attend 21 flight school and pursue a career in aviation. ECF 1-2 at ¶¶ 1, 4. Although Morales claims that he 22 met “every medical standard” to be eligible for a first-class airman medical certificate, the FAA 23 requested additional medical documentation and evaluations.1 Id. at ¶1. Morales claims that these 24 requests “go[] beyond the law since [he] meets all the requirements for a . . . . certificate.” Id. 25

26 1 The additional information was necessary to determine if Morales met the required medical standards in light of a past alcohol-related offense. Kabaza-Gomez Decl., Def.’s Ex. 1, ECF No. 7-1 at ¶4. 1 Morales refused to undergo the additional medical evaluations. Id. at ¶¶ 1–3. He claims that he 2 furnished all of the requested records he could provide, but did not provide any hospitalization 3 or other clinical/medical records because none exist. Id. at ¶ 2. Morales was not issued medical 4 certification. Id. at ¶ 1. 5 Morales filed his complaint in the Eighth Judicial District Court of Clark County, 6 Nevada on August 22, 2023. ECF No. 1-2. Obrien removed the case to this court on September 7 18, 2023. ECF No. 1. 8 II. Legal Standard 9 A motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) challenges a court’s 10 subject matter jurisdiction. Pursuant to 12(b)(1), a motion to dismiss for lack of subject matter 11 jurisdiction will be granted if the complaint fails to allege sufficient facts to establish 12 jurisdiction. See Savage v. Glendale Union High Sch. Dist. No. 205, 343 F.3d 1036, 1039 n.2 (9th Cir. 13 2003). In considering a 12(b)(1) motion, the court is not restricted to the face of the pleadings 14 but may review any evidence to resolve factual disputes concerning the existence of jurisdiction. 15 McCarthy v. United States, 850 F.2d 558, 560 (9th Cir. 1988). 16 III. Discussion 17 A. The Federal Aviation Act. 18 The FAA requires pilots to hold both a medical certificate and a pilot certificate. 19 14 C.F.R. § 61.3(c). These certificates are issued by the FAA administrator, who certifies pilots 20 “qualified for, and physically able to perform the duties related to [their] position.” 49 U.S.C. 21 § 44703(a). The decision to issue a medical certificate is “based on medical examination and 22 evaluation of the person’s history and condition.” 14 C.F.R. § 67.3. The FAA administrator may 23 delegate their duty to issue or deny medical certificates to the Federal Air Surgeon and their 24 representatives. 14 C.F.R. § 67.407(a)(b). Thus, the denial of a medical certificate by aeromedical 25 certification division manager is “considered to be a denial by the [FAA] [a]dministrator.” 26 14 C.F.R. § 67.409(b)(3). 1 Congress created an appeal process for adverse medical certificate determinations. 2 Gladden v. Berry, 2018 U.S. Dist. LEXIS 229851, at *16 (D. Alaska Aug. 8, 2018). In order to appeal 3 an adverse medical certificate determination, the applicant must first seek reconsideration from 4 the FAA. Id. (citing 14 C.F.R. § 67.407(c)). If the applicant is still aggrieved after the FAA’s final 5 determination, the applicant may appeal to the National Transportation Safety Board (NTSB). 6 Id. (citing 49 U.S.C. § 44703(d)(1)(2)). The NTSB reviews the denial under two levels of review: 7 first, the appeal goes to an NTSB administrative law judge (ALJ) who issues a decision, then to 8 the full board who reviews the ALJ’s order. See 49 C.F.R. §§ 821.37–821.50. If the applicant is still 9 aggrieved, the applicant may then file a petition for review in a U.S. Court of Appeals. Id. (citing 10 49 U.S.C. § 46110(a)(c)). A district court generally does not have subject matter jurisdiction over 11 the FAA’s denial of a medical certification unless the claimant first exhausted. Gladden, 2018 U.S. 12 Dist. LEXIS 229851 (claimant’s failure to exhaust administrative remedies barred district court’s 13 jurisdiction over challenge to denial of claimant’s medical certification). 14 However, district courts have jurisdiction over claims that “broadly challenge[] the 15 constitutionality of” the procedures that led to the issuance of the adverse FAA order. Mace v. 16 Skinner, 34 F.3d 854, 858 (9th Cir. 1994). Still, for “a district court or court of appeals to have 17 jurisdiction over direct challenges, the FAA order at issue must be final or fully exhausted.” 18 Gladden, 2018 U.S. Dist. LEXIS 229851, at *16 (citing Americopters, LLC v. F.A.A., 441 F.3d 726, 735- 19 36 (9th Cir. 2006)). The denial of a medical certification is not a final order; the applicant must 20 first seek reconsideration of the denial to make it a final order ripe for judicial review. See 21 Gladden, 2018 U.S. Dist. LEXIS 229851, at *18 (“[T]his Court finds a final order does not exist for” 22 for the denial of the applicant’s “airman medical certification as [the applicant] did not seek 23 reconsideration of the decision with the FAA.”) 24 25 26 1 B. Defendant’s motion to dismiss is granted because there is no final FAA order 2 and Morales failed to exhaust. 3 Morales’ failure to procure a final order is fatal to this court’s ability to exercise 4 jurisdiction over this action. While a liberal construction of Morales’ pleadings2 could interpret 5 several possible constitutional challenges—(1) the constitutionality of the FAA’s medical 6 examination request (ECF No. 1-2 at ¶ 3); (2) the need for a medical certificate as violating a 7 fundamental liberty (id. at ¶¶ 3, 4); (3) an alleged due process violation (ECF No.

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Bluebook (online)
Morales v. Federal Aviation Administration Aerospace Medical Certificate Division Manager David M. O'Brien, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morales-v-federal-aviation-administration-aerospace-medical-certificate-nvd-2024.