Reid v. Mayorkas

CourtDistrict Court, District of Columbia
DecidedNovember 27, 2024
DocketCivil Action No. 2024-2186
StatusPublished

This text of Reid v. Mayorkas (Reid v. Mayorkas) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Reid v. Mayorkas, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

TONY J. REID, et al., : : Plaintiffs, : Civil Action No.: 24-2186 (RC) : v. : Re Document No.: 12 : ALEJANDRO N. MAYORKAS, : Secretary of the Department of Homeland : Security, et al., : : Defendants. :

MEMORANDUM OPINION

DENYING PLAINTIFFS’ MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY

INJUNCTION

I. INTRODUCTION

Federal law codified at 46 U.S.C. § 7511 instructs the United States Coast Guard to deny

merchant mariner licenses and credentials to individuals convicted of certain sex offenses.

Plaintiffs sued the Department of Homeland Security and the Coast Guard, claiming that the

Coast Guard incorrectly applied this provision to their requests to renew their Merchant Mariner

Credentials (“MMCs”) in violation of the Administrative Procedure Act (“APA”), the Merchant

Marine Act of 1936, and the Fifth Amendment Due Process Clause. Plaintiffs move for a

temporary restraining order and preliminary injunction suspending this practice. The Court

denies Plaintiffs’ motion because they do not demonstrate a likelihood of success, and the public

interest weighs against injunctive relief. II. BACKGROUND

A. Statutory Background

“To legally work aboard a United States merchant marine vessel, individuals must

receive [an MMC] from the National Maritime Center (‘NMC’), the licensing authority of the

United States Coast Guard.” Clifford v. U.S. Coast Guard, 915 F. Supp. 2d 299, 303 (E.D.N.Y.

2013) (citing 46 C.F.R. §§ 10.209, 10.225). Federal law provides for the issuance of licenses,

certificates, and documents to merchant seamen, see 46 U.S.C. § 7101(c), establishes general

requirements for issuance of those documents, see id. § 7101(e), and defines associated

procedures, see id. §§ 7501–11. A license “is valid for a 5-year period and may be renewed for

additional 5-year periods.” Id. § 7106(a); see also 46 C.F.R. § 10.205(a) (“An MMC is valid for

a term of 5 years from the date of issuance.”). An MMC “is a credential combining the elements

of the merchant mariner’s document (MMD), merchant mariner’s license (license), and

certificate of registry (COR),” as well as international training and certification standards. 46

C.F.R. § 10.201(a).

In response to reports of sexual assault and sexual harassment within the U.S. Merchant

Marine Academy, Congress recognized “the need for systemic maritime industry mechanisms

for reporting and investigating claims of sexual assault and sexual harassment, as well as

mechanisms for punishing offenders.” H.R. Rep. No. 117-282, at 43 (2022). Among other

changes, H.R. 6865, 117th Cong. (2022), proposed provisions to “ban[ ] individuals convicted of

sexual assault from receiving a merchant mariner credential and revoke[ ] the credentials of those

convicted of sexual assault in the previous ten years.” H.R. Rep. No. 117-282, at 43. Congress

soon enacted these measures in the James M. Inhofe National Defense Authorization Act for

2 Fiscal Year 2023 (“NDAA”). See §§ 11601–11, Pub. L. No. 117-263, 136 Stat. 2395, 4145–56

(2022). Two of those provisions are relevant here.

First, Congress barred the Coast Guard from issuing credentials—including MMCs—to

individuals convicted of certain sex offenses. “A license, certificate of registry, or merchant

mariner’s document authorized to be issued under this part shall be denied to an individual who

has been convicted of a sexual offense prohibited under” either “chapter 109A of title 18” or “a

substantially similar offense under State, local, or Tribal law.” Id. § 11602 (codified at 46

U.S.C. § 7511). Chapter 109A of Title 18 comprises provisions criminalizing sexual abuse, see

18 U.S.C. § 2242; aggravated sexual abuse, see id. § 2241; sexual abuse of a minor, a ward, or an

individual in Federal custody, see id. § 2243; and abusive sexual contact, see id. § 2244. 1

Second, Congress provided a process for revocation of credentials when an individual is

the subject of an “official finding” of sexual harassment or sexual assault. See NDAA § 11603

(codified at 46 U.S.C. § 7704a). An “official finding” includes “a legal proceeding or agency

finding or decision that determines the individual committed sexual harassment or sexual assault

in violation of any Federal, State, local, or Tribal law or regulation.” 46 U.S.C.

§ 7704a(c)(1)(A). It also includes a finding by the Coast Guard following an investigation. See

id. § 7704(c)(1)(B). If it is shown at a hearing that an individual is the subject of an official

finding of sexual harassment within the previous five years, the individual’s credentials “may be

suspended or revoked.” Id. § 7704(a). Where the finding includes sexual assault and occurred

within the past 10 years, the individual’s credentials “shall be revoked.” Id. § 7704(b).

1 The mandatory bar found in § 7511 does not apply to individuals convicted of abusive sexual contact under 18 U.S.C. § 2244(b) or a substantially similar offense under State, local, or Tribal law. See 46 U.S.C. § 7511(b). Instead, a license, certificate of registry, or merchant mariner’s document “may” be denied when that conviction occurred “within 5 years before applying for the license.” Id.

3 B. Factual Background

On May 23, 2023, the Coast Guard issued Policy Letter No. 03-23 (“Policy Letter”) to

the National Maritime Center to “provide[ ] guidance on safety and suitability determinations for

applicants for [MMCs] with convictions for sexual assault.” Ex. 1 to Pls.’ Mot. for TRO and

Prelim. Inj. at 1 (“Pls.’ Mot.”), ECF No. 12. The letter explains that “[t]he Coast Guard will use

this policy when evaluating applications for a MMC,” id. at 35, and provides the Coast Guard’s

interpretation of § 7511, see id. at 36–37. 2 The policy letter explains that it “is not a substitute

for applicable legal requirements, nor is it itself a regulation.” Id. at 37. The letter states the

“guidance represents the Coast Guard’s current thinking on this topic” and is intended to assist

“in applying statutory and regulatory requirements.” Id.

Plaintiffs are three merchant mariners whose MMC renewal applications were denied due

to prior sexual assault convictions. Plaintiff Tony J. Reid was first issued an MMC in 2018. See

Reid Decl. at 50, ECF No. 12. In 2023, the Coast Guard denied his application to renew his

MMC, citing § 7511(a) and a “1996 Washington state conviction for the rape of a child.” Ex. 2

to Pls.’ Mot. at 40, ECF No. 12. The Coast Guard explained that “[t]he law prevents issuance of

an MMC to individuals with certain sexual offense convictions.” Id. Plaintiff Brandon A.

Phillips received an MMC in 2014 and applied for a renewal in 2024.

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