Background
Lindsay Dyda, a Michigan resident with a religious belief preventing her from obtaining a Social Security Number, was denied a Commercial Learner Permit by the Michigan Department of State. Federal regulations generally require applicants to provide a Social Security Number. Dyda sued under the Civil Rights Act of nineteen eighty three, claiming the denial violated the Free Exercise Clause of the First Amendment. After the lawsuit began, the Federal Motor Carrier Safety Administration issued guidance clarifying that states do not need to verify a Social Security Number if the applicant does not have one due to a religious exemption. The Michigan Department of State changed its policy to allow the waiver.
The court’s reasoning
The court held that the requests for declaratory and injunctive relief were moot because the defendants voluntarily complied with federal guidance allowing the waiver of the Social Security Number requirement. The court also affirmed qualified immunity for the individual defendant as no clearly established right was violated.
Once the issues presented are no longer live or the parties lack a legally cognizable interest in the outcome, our jurisdiction ends, and a lawsuit becomes moot.
Cal. Palms Addiction Recovery Campus, Inc. v. United States, 158 F.4th 726, 730 (6th Cir. 2025)
What it means going forward
The Michigan Department of State will allow applicants with religious exemptions to waive the Social Security Number requirement in Commercial Learner Permit and Commercial Driver License applications.