Background
Lindsay Dyda has a sincerely held religious objection to obtaining a Social Security Number and received a religious exemption from the Social Security Administration. In March 2024, she applied in Michigan for a Commercial Learner’s Permit, a prerequisite to a Commercial Driver’s License. The Michigan Department of State denied the application because federal regulations appeared to require every applicant to provide an SSN.
Help desk worker Josette Tabor escalated Dyda’s case, and state officials sought guidance from federal regulators. After initially receiving guidance that the SSN requirement was mandatory, Michigan received a September 2025 letter from the Federal Motor Carrier Safety Administration clarifying that the state could waive the requirement for an applicant who lawfully lacked an SSN. Michigan then agreed to process Dyda’s application without an SSN and to honor her earlier test results, while requiring her to satisfy any other applicable licensing requirements.
Dyda sued state officials under 42 U.S.C. § 1983, seeking declaratory and injunctive relief and damages based on the Free Exercise Clause. The district court dismissed her prospective-relief claims as moot and held that Tabor was entitled to qualified immunity. Dyda appealed.
The Court’s Holding
The Sixth Circuit affirmed. It held that Dyda’s requests for declaratory and injunctive relief were moot because Michigan no longer required her to provide an SSN and had changed its policies to accommodate applicants with religious exemptions. Whether Dyda ultimately receives a permit now depends on completing any remaining application requirements, not on obtaining an SSN. Her requested declaration concerning the defendants’ past conduct could not sustain a live controversy.
The court also held that Michigan’s voluntary cessation of the challenged conduct did not preserve the dispute. The state changed course promptly in response to authoritative federal guidance, was implementing broader procedural changes, and had sought clarification from federal officials even before the lawsuit began. The record therefore showed no reasonable expectation that Michigan would resume its former policy.
Finally, Tabor was entitled to qualified immunity because no clearly established law notified a reasonable official that enforcing the facially neutral SSN requirement under these circumstances violated the Free Exercise Clause. The governing regulations appeared mandatory, and existing precedent could reasonably be read to permit enforcement of a neutral, generally applicable SSN requirement. Because the absence of a clearly established right was apparent from the complaint, the district court properly resolved qualified immunity at the motion-to-dismiss stage.
Key Takeaways
- A claim for prospective relief becomes moot when intervening events eliminate the challenged barrier and the requested injunction would have no practical effect.
- A government defendant’s policy change can moot a case when the change is genuine and the record shows no fair prospect that the challenged conduct will recur.
- Officials receive qualified immunity when existing law does not clearly establish that their reasonable interpretation and enforcement of an apparently mandatory statute or regulation is unconstitutional.
Why It Matters
The decision illustrates how authoritative agency guidance issued during litigation can eliminate a live constitutional dispute, particularly when the government promptly adopts the guidance and implements corresponding policy changes. A plaintiff’s continued lack of the ultimate benefit does not preserve the controversy when a different, unchallenged requirement now stands between the plaintiff and that benefit.
The ruling also emphasizes that broad First Amendment principles may be insufficient to defeat qualified immunity. Plaintiffs must identify precedent particularized enough to warn an official that the specific conduct at issue was unlawful, especially when the official reasonably relied on facially neutral statutory and regulatory language.