Coalition of Automobile Registration Safety

An ID rule the Legislature never wrote.

CARS is a coalition of Texas vehicle owners, dealers, lenders, insurers, and communities. TxDMV has narrowed who may register a vehicle in Texas — a line the statute leaves to the Legislature, not the agency. We contend the rule exceeds TxDMV's authority and reaches back to unsettle registrations and the loans behind them. We're challenging it, under Texas law, in Texas courts.

Constitutional Rights Public Safety Economic Vitality Counsel Cobb & Gervasi
The Issue

A rule that reaches backward.

For years, Texans registered and renewed vehicles using a range of accepted identification, including a standalone foreign passport. TxDMV has now narrowed acceptable ID to documents that prove lawful presence — adopting amendments to 43 TAC Chapter 217. The agency's authority comes from a decades-old statute requiring that a registration application be accompanied by “personal identification as determined by department rule.” CARS contends that delegation lets the agency decide which documents are acceptable — not add a lawful-presence test for a statute that speaks only of a “resident.” The initial-registration requirements took effect March 5, 2026; the renewal requirements follow on January 1, 2027, and will bar renewal for owners who cannot produce the newly required documents.

01

Bought & Registered in Good Faith

Texans acquired their vehicles and registered them under the rules in place at the time — rights CARS contends are settled property interests the State cannot simply revoke.

02

TxDMV Moves the Line

Guidance went out in November 2025 without notice-and-comment. The agency then proposed (Dec. 5, 2025) and adopted amendments to 43 TAC §§ 217.22, 217.26, 217.28, and 217.29 — over sustained county and industry opposition.

03

Real Consequences

For owners who cannot produce the newly required documents, a vehicle becomes unregistrable — and a vehicle that cannot be registered cannot be lawfully driven on Texas roads. CARS contends they received no meaningful notice or chance to be heard.

04

CARS Forms

Owners, dealers, lenders, insurers, repair shops, title companies, tax assessors, and families unite under a Texas nonprofit to challenge the rule.

How We Got Here

The rule's path — by the record.

Every date and citation below comes from the official rulemaking record. Sources are linked in Documents.

November 2025
Guidance by bulletin. TxDMV begins tightening accepted ID through communications to counties — 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.
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

When Texans are blocked from registering, many are pushed to keep driving unregistered — and too often uninsured. CARS contends a rule that forces more untracked vehicles onto Texas roads makes everyone less safe, regardless of background or status.

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.

The Legal Case

The case against the rule.

CARS contends TxDMV's rule cannot stand — it exceeds the authority the Legislature granted, it disregards constitutional protections, and it inflicts concrete, particularized injury on the lenders and owners who have standing to challenge it. The points below are the coalition's contentions, summarized for public information; they are not legal advice.

Administrative Procedure Act

Exceeds Statutory AuthorityTransportation Code § 502.040 lets TxDMV decide what personal identification a registrant presents. It does not authorize the agency to graft a new substantive condition — proof of lawful immigration status — onto a statute that conditions registration on Texas residency. A grant to specify acceptable ID is not a license to rewrite who may register.
No Rational FitThe agency justifies the rule as fraud prevention, yet it rejects identity documents long trusted as valid and burdens citizens, existing registrants, lenders, and businesses alike. CARS contends the rule reaches far wider than any problem the agency has shown — severing the connection between ends and means that the law demands.
Process as AfterthoughtTxDMV announced and enforced the new policy by bulletin months before it adopted any rule. CARS contends an agency that decides and acts first, then treats notice-and-comment as a formality, has not genuinely weighed the objections the law requires it to consider.

Constitutional Claims

Retroactive ImpairmentThe initial-registration requirements are already in force, reaching owners who registered and lenders who lent in good faith under the prior rules. CARS contends that upsetting already-vested registrations and liens — without meaningful notice or a chance to be heard — offends due process.
Settled RelianceFor decades the State accepted identification it now rejects. Texans bought, and lenders financed, in reliance on that settled framework. CARS contends an abrupt reversal applied to completed transactions cannot be squared with fundamental fairness.
Equal Protection (preserved)To the extent the rule, in operation, draws lines among similarly situated Texans without adequate justification, the coalition preserves an equal-protection challenge.

Standing & Stakes

Concrete, Particularized InjuryThis is no abstract dispute. Lenders hold paper on vehicles the rule can render unregistrable for a subset of borrowers — a direct hit to collateral value that gives the coalition's members a real, personal stake and the standing to be heard.
A Texas Case in Texas CourtsCARS intends to bring this challenge under the Texas Administrative Procedure Act and Texas law, before courts that resolve agency disputes every day.

These are the coalition's contentions, summarized for public information. They are not admissions or legal advice, and the claims, parties, relief, and forum remain subject to investigation and may change before any filing.

How It Works

Coordinated strategy. Individual control.

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

Step 01

You Join & Contribute

Sign the Coalition Agreement and make your participation contribution. One-time or recurring options are available.

Step 02

CARS Coordinates

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

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 binds you without written consent. You receive at least 30 days to review any recommended offer, with full opt-out rights.

Join the Coalition

Choose your contribution. Draft tiers

Contributions fund legal fees, expert witnesses, filing costs, and advocacy that amplifies the voices of affected communities, businesses, and families. All contributions are non-refundable. CARS applies funds to its mission of challenging a registration ID rule it contends is unlawful and retroactive. Tier amounts below are placeholders to finalize with the coalition's founding members.

Entry
$1,000
Standard
$5,000
Advocate
$10,000
Champion
$25,000
Patron
$50,000
Founder
$100,000
Monthly · Standard
$1,000/mo
Monthly · Advocate
$2,500/mo

Contribute to CARS

Make a one-time or recurring contribution — choose a level above or enter any amount in the secure form. After contributing, you'll receive the Coalition Agreement to sign.

Secure contribution form — coming soon. One-time and recurring giving by card or bank, with an emailed receipt. To wire up

Tax status: CARS is intended to be organized as a Texas nonprofit corporation pursuing 501(c)(4) tax-exempt status. Contributions are not tax-deductible as charitable contributions for federal income tax purposes. Please consult your tax advisor.

Leadership

Board of Directors Names TBD

The Board oversees coalition decisions, coordinates with legal counsel, and manages communications among members. Decisions are made by majority vote; the Chair holds a casting vote in the event of deadlock. Founding directors will be named here.

Director Name

Chair · Board of Directors

Director Name

Director

Director Name

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
Open →
Adopted Rule — 43 TAC Ch. 217 (§§ 217.22, .26, .28, .29)Texas Register, adopted rules · Feb. 27, 2026
Open →
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
Open →

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.

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.

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. Membership terms are governed by the Coalition Agreement.

Can I settle on my own terms?

Yes. No settlement binds you without your written consent. Members receive at least 30 days to review any recommended settlement offer, with full opt-out rights as to their individual claims.

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 happens to unspent contributions when the case resolves?

After resolution and payment of all expenses (including final tax-return and wind-down costs), remaining funds are disposed of at the Board's discretion in accordance with CARS's organizational documents and applicable law. No individual member has a right to a refund.

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 member accepts these risks as a condition of participation.

Is my contribution tax-deductible?

CARS is intended to be organized as a Texas nonprofit corporation pursuing 501(c)(4) tax-exempt status. Contributions are NOT tax-deductible as charitable contributions for federal income tax purposes. Each member's specific tax circumstances may vary; please consult your own tax attorney or advisor.