Truckers United for Safety v. Mead

Opinion for the Court filed by Chief Judge Edwards.

In keeping with its mission to enforce motor carrier safety regulations, the Office of Motor Carriers (“OMC”) initiated compliance review investigations into appellants’ record keeping practices. As part of that effort, the Department of Transportation’s Office of Inspector General (“DOT OIG”) was engaged to use its purported search and seizure authority to obtain appellants’ business records. Under the legal framework in effect at the time of the underlying events, the Inspector General Act of 1978, Pub. L. No. 95-452, 92 Stat. 1101 (1978) (“Inspector General Act” or “Act”), the Inspector General (“IG”) had no authority to engage in the kinds of criminal investigations at issue here-criminal investigations that are at the heart of an agency’s general compliance enforcement responsibilities. We therefore hold that appellants are entitled to the return of records and other property seized from them during the IG’s ultra vires investigations and seizures.