CARS
Coalition of Automobile Registration Safety

An ID rule the Legislature never wrote.

Registration keeps Texas roads safe.
DMV’s ID rule puts Texas drivers at risk.

The Issue

A rule that reaches backward.

A rule made by an agency, applied backward:

  • For years, Texans registered and renewed using a range of accepted ID — including a standalone foreign passport.
  • TxDMV — not the Legislature — narrowed acceptable ID to documents proving lawful presence, amending 43 TAC Chapter 217.
  • The statute it leans on asks only for “personal identification” from a “resident” — CARS contends it never authorized a lawful-presence test.
  • In force now for new registrations (March 5, 2026); renewals follow January 1, 2027 — reaching Texans who registered in good faith under the old rules.
Registration & Safety

Registration is a safety system — not paperwork.

DMV says the rule protects public safety, but it does the opposite. Registration is the safety system: it's designed to keep every car insured, traceable, and reachable for recalls. Barriers to registration don't keep unregistered cars off the road — they put unregistered cars on the road — but untracked and outside the safety system.

DMV’s ID rule = fewer registrations = less safety.

“The registration requirement and, more pointedly, the related annual inspection requirement… are designed to keep dangerous automobiles off the road… essential elements in a highway safety program.”
— U.S. Supreme Court, Delaware v. Prouse, 440 U.S. 648, 658 (1979)
01

The Supreme Court's own words

The Court has recognized registration and inspection as tools “to keep dangerous automobiles off the road” — the same public-safety interest the agency now invokes to defend the rule.

02

The recall system's address book

Manufacturers identify and notify current owners of safety-defect recalls using state vehicle-registration and title records. A vehicle that drops off the registration rolls is far harder to reach — the rule pushes it toward the edge of the defect-repair system, not off the road.

03

Texas's insurance checkpoint

Through TexasSure, Texas verifies financial responsibility at registration and renewal — by the State's own design. Cut registration and you cut lawful drivers out of the State's own uninsured-motorist enforcement.

Sources: Delaware v. Prouse, 440 U.S. 648 (1979); NHTSA on registration-based recall notification; TexasSure. Provided for public information; not legal advice.

Our Mission

What we believe.

CARS is a Texas nonprofit corporation built to protect constitutional rights, safeguard public safety, and defend the economic vitality of Texas communities against unlawful and retroactive government overreach. Our mission rests on three convictions.

I

Vehicle Ownership Is a Property Right

When government acts retroactively to extinguish a lawfully acquired right — without notice, without hearing, and without remedy — it violates the fundamental principles of due process our legal system is built upon.

II

Public Safety Belongs to Everyone

The U.S. Supreme Court calls registration and inspection “essential elements in a highway safety program.” Delaware v. Prouse (1979) The chain is direct: this ID rule means fewer registered vehicles, and fewer registered vehicles means less safety — recalls that can't reach owners, insurance that goes unverified, cars the State can no longer trace. Texans blocked from registering keep driving anyway, now outside that system. CARS contends the rule makes every Texas road less safe.

III

Economic Harm to Any Texan Is Harm to All

The rule is already devastating dealers, lenders, insurers, repair shops, title companies, county tax assessors, and working families — eliminating jobs, triggering defaults, and draining the revenue Texas depends upon.

We do not ask for special treatment. We ask for due process.
We ask for safety. We ask for Texas to do the right thing.

How We Got Here

The rule's path — by the record.

Dates below come from the official rulemaking record and TxDMV's own communications. Sources are linked in Documents.

November 3, 2025
A legislator's letter. State Rep. Brian Harrison writes the TxDMV board that non-citizens are registering vehicles, and threatens legislation if the agency doesn't act — a letter, not a law.
November 18, 2025
The agency acts by bulletin. TxDMV issues a statewide Registration & Title Bulletin tightening accepted ID — moving on its own, before any formal rule.
December 5, 2025
Rule proposed. The amendments are published for public comment in the Texas Register (50 TexReg 7868).
January 2026
Opposition on the record. County tax assessor-collectors, the Texas Automobile Dealers Association, and legislators object during the comment period.
February 27, 2026
Amendments adopted. TxDMV adopts changes to 43 TAC §§ 217.22, 217.26, 217.28, and 217.29.
March 5, 2026
In effect — initial registration. The new ID requirements apply to initial vehicle registrations statewide.
January 1, 2027
In effect — renewals. The new ID requirements extend to registration renewals.
How It Works

Coordinated strategy.
Individual control.

CARS coordinates litigation and lobbying on behalf of its participants. Each participant keeps its individual claims, and no settlement binds a participant without written consent.

Step 01

You Join

Sign the Coalition Agreement — joining is free, with no contribution required. If you choose to help fund the fight, one-time or recurring contributions are welcome.

Step 02

CARS Coordinates

The Board manages communications with counsel and sets strategy across the coalition.

Step 03

Counsel Litigates

Cobb & Gervasi files and prosecutes the case. You stay informed through CARS at every stage.

Step 04

You Decide on Settlement

No settlement can release your individual claims without your written consent, and you always retain the right to pursue them independently. The CARS Coalition Agreement sets out the review process for any recommended resolution.

Join the Coalition

Join the coalition.

Joining is free — no contribution is required to become a participant, so every affected Texan can stand with us. Contributions are welcome and fund the legal fight — fees, expert witnesses, filing costs, and advocacy — but they’re entirely optional. Any contribution made is non-refundable.

Join the coalition

Tap an option to start — we'll fill it in on the form below. Joining is free; a contribution is optional.

Join at no cost — contribution optional
$0.00

Add a contribution (optional)

Supporter
$25
Friend
$50
Ally
$100
Sustaining
$500
Benefactor
$1,000

Founding & institutional support

Standard
$5,000
Advocate
$10,000
Champion
$25,000
Patron
$50,000
Founder
$100,000

Monthly

Monthly · Supporter
$25/mo
Monthly · Ally
$100/mo
Monthly · Standard
$1,000/mo
Monthly · Advocate
$2,500/mo

Contributing to CARS

Contributions are optional and fund the fight. Secure online giving — one-time or recurring, by card or bank — opens shortly. In the meantime, join (free) or note an intended contribution just below, and we'll send you the CARS Coalition Agreement.

Secure contribution form — opening soon.

Tax status: CARS is a Texas nonprofit corporation that intends to operate as a tax-exempt social welfare organization under Section 501(c)(4) of the Internal Revenue Code. Contributions are not tax-deductible as charitable contributions for federal income tax purposes. Please consult your tax advisor.

Leadership

Board of Directors

The Board oversees coalition decisions, coordinates with legal counsel, and manages communications among participants.

GF

George Fussell Sr.

Chair · Board of Directors

AL

Anthony Lazzari

Director

JS

John Schoolcraft

Director

Legal Representation

Our Counsel: Cobb & Gervasi

CARS has retained Cobb & Gervasi — an Austin government-litigation boutique. Founding partners Bill Cobb and Alexa Gervasi bring insight from both sides of Texas government disputes — one who built cases inside Texas government, the other who has spent her career challenging government overreach in court.

  • Direct TxDMV experience — representing manufacturers, distributors, dealers, and retailers before the agency, with first-hand knowledge of how it makes rules.
  • Bill Cobb — former Special Assistant to Attorney General Greg Abbott and Deputy Attorney General for Civil Litigation, where he managed 300 attorneys across 10 litigation divisions. Recognized by ChambersUSA for a “unique perspective on state regulation,” and in Best Lawyers in America (2015–2024).
  • Alexa Gervasi — Fifth Circuit clerk to Judge Don Willett and Third Circuit clerk to Judge D. Michael Fisher, and an attorney at the Institute for Justice, the nation's premier civil-liberties firm fighting government overreach. Georgetown Law, cum laude; admitted to the U.S. Supreme Court bar.
  • Together, the firm has practiced before and litigated against almost every Texas state agency, in state and federal court — from SOAH hearings through district court and appeal.
“The agency rewrote the rules of registration retroactively — without the authority, the record, or the due process the law requires. Texans are entitled to a ruling that restores lawful standards and the rights it took away.”
Cobb & Gervasi, on behalf of CARS
Litigation

Court Filings Pre-filing

The coalition's challenge is in preparation. CARS intends to bring it under the Texas Administrative Procedure Act and Texas law. Public filings will be posted here as the litigation proceeds.

Petition for Declaratory & Injunctive ReliefTo be filed · Texas district court (anticipated)
Coming soon
Application for Temporary InjunctionTo be filed · expedited consideration anticipated
Coming soon
Supporting Appendix & DeclarationsTo be filed
Coming soon

Documents will be provided for public information only and do not constitute legal advice. The official, complete docket is maintained by the court once a case is filed.

The Record

Read the primary sources.

We're not asking anyone to take our word for it. Every factual claim on this site traces to the official record below — the agency's own bulletin, the adopted and proposed rules in the Texas Register, and the statute the agency relies on.

TxDMV Registration & Title Bulletin #001-26Official agency bulletin · Feb. 18, 2026 · PDF
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Adopted Rule — 43 TAC Ch. 217 (§§ 217.22, .26, .28, .29)Texas Register, adopted rules · Feb. 27, 2026
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Proposed Rule (50 TexReg 7868)Texas Register, proposed rules · Dec. 5, 2025
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Tex. Transportation Code Ch. 502 (§ 502.040)The statutory authority the agency relies on
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Delaware v. Prouse, 440 U.S. 648 (1979)U.S. Supreme Court — registration & inspection are “essential elements in a highway safety program”
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TexasSure — Insurance VerificationTexas verifies financial responsibility through vehicle registration
Open →
TxDMV Clarification on Acceptable Identification — Foreign Passport & DHS DocumentationTxDMV message archive · Nov. 25, 2025
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Links open official government sources in a new tab. Provided for public information only; not legal advice.

Common Questions

Frequently asked.

If you don't see your question here, contact the Board — we'll get back to you within two business days.

Isn't this rule about public safety?

The State says so — but registration is the safety system. The U.S. Supreme Court calls registration and inspection “essential elements in a highway safety program” (Delaware v. Prouse): it ties each vehicle to an insured, accountable owner, to the recall network, and to Texas's own insurance verification (TexasSure). This DMV rule takes no car off the road — it drives more unregistered, untracked vehicles onto it, outside that system. Fewer registered vehicles means more danger for everyone, not less.

Does joining CARS mean I give up my individual rights?

No. CARS acts as an administrative and coordination entity only. You retain your individual claims and the right to pursue them independently. This is not a class action — no court outcome automatically binds you unless a court of competent jurisdiction so orders, or you individually consent to a settlement.

Do I have to contribute to join?

No. Joining is free — no contribution is required to become a participant. Contributions are welcome and fund the litigation (legal fees, expert witnesses, filing costs, and advocacy), but they are entirely optional. You can join at no cost and contribute later, or not at all.

Who can join the coalition?

CARS is open to everyone harmed by the rule — vehicle owners, dealers, lenders and lienholders, the auto insurance industry, repair facilities, title companies, county tax assessors, and working families. Joining is free, and participation terms are governed by the CARS Coalition Agreement.

Can I settle on my own terms?

Yes. CARS — not individual participants — is the party to the coalition’s case. Nothing CARS does can settle or release your individual claims without your written consent, and you always retain the right to pursue them independently. The CARS Coalition Agreement sets out the review process for any recommended resolution.

Who is our legal counsel?

Cobb & Gervasi serves as primary litigation counsel. The firm brings deep experience in Texas administrative and constitutional litigation, and may associate additional attorneys on a contract basis to support the litigation.

What litigation risks should I be aware of?

Litigation involves inherent risks: actual fees and expenses may exceed any budget estimate; proceedings may take longer than anticipated; an unfavorable ruling could establish adverse precedent; and even a favorable ruling may not result in the relief sought if the agency takes further legislative or administrative action. Each participant accepts these risks as a condition of participation.

Is my contribution tax-deductible?

CARS is a Texas nonprofit corporation that intends to operate as a tax-exempt social welfare organization under Section 501(c)(4) of the Internal Revenue Code. Contributions are NOT tax-deductible as charitable contributions for federal income tax purposes. Your specific tax circumstances may vary; please consult your own tax attorney or advisor.