Case Explained: FLORIDA EAST COAST RAILWAY LLC v. FEDERAL RAILROAD ADMINISTRATION ADMINISTRATOR, FEDERAL RAILROAD ADMINISTRATION UNITED STATES DEPARTMENT OF TRANSPORTATION INTERNATIONAL ASSOCIATION OF SHEET METAL, AIR RAIL AND TRANSPORTATION WORKERS- TRANSPORTATION DIVISION USCA11 Case: 24-11076 Document: 97-1 Date Filed: 08/11/2026 Page: 1 of 93 2

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-11 The Eleventh Circuit denied consolidated petitions for review filed by various railroads and industry associations challenging the Federal Railroad Administration’s (FRA) 2024 “Crew Size Rule.” The court held that the FRA acted within its statutory authority under the Federal Railroad Safety Act of 1970, which empowers the Secretary of Transportation to issue safety regulations “as necessary,” interpreting this phrase as granting broad discretion rather than imposing a strict evidentiary bar requiring quantitative proof of necessity. Applying the Administrative Procedure Act’s arbitrary and capricious standard, the court found the FRA reasonably exercised its authority by relying on predictive judgments, safety research regarding cognitive demands, public comments detailing close calls, and trends such as increasing train lengths and human-factor accidents to justify the rule. The court rejected arguments that the agency failed to consider labor costs or violated the “change-in-position doctrine” when reversing its 2019 decision not to regulate, noting that the 2019 order had been vacated by the Ninth Circuit and thus did not constitute a binding prior policy requiring heightened justification. Additionally, the court ruled that the rule did not conflict with the Rail Safety Improvement Act’s risk reduction program and that the FRA’s failure to meet a statutory 12-month procedural deadline did not warrant vacatur because Congress did not specify such a consequence for noncompliance. Consequently, the petitions were denied, leaving the Crew Size Rule in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.