Legal Interpretations
Shomloo 1998
Summary
The Question
Is an administrative 30-day driver's license suspension for exceeding Oregon's blood alcohol limit a reportable "motor vehicle action" under 14 CFR 61.15?
Background
An attorney's client faced a mandatory 30-day driver's license suspension based on a blood alcohol level above the Oregon limit.
The FAA’s Interpretation
It appears so. 14 CFR 61.15(c)(2) defines a motor vehicle action to include suspension of a license for a cause related to operating a motor vehicle while intoxicated, without requiring a criminal conviction. If the suspension is a motor vehicle action, it must be reported under 14 CFR 61.15(e). One action carries no adverse consequences, but two within 3 years are a basis for adverse action under 14 CFR 61.15(d).
- Requester
- Shomloo
- Issued
- October 2, 1998
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
October 2, 1998
David N. Shomloo, Esq.
Shomloo & Shomloo Merchant
Hotel Building 222 NW Davis
Suite 402
Portland, OR 97209
Dear Mr. Shomloo:
This responds to your letter of September 24, 1998, regarding driver's license suspension. Your client faces a mandatory 30-day suspension based on a blood alcohol level exceeding the Oregon limit.
Federal Aviation Regulation section 61.15 (FAR 61.15) (14 C.F.R. section 61.15.) addresses this subject. A copy is attached. The relevant subsection appears to be FAR 61.15(c)(2), which defines a "motor vehicle action" to include suspension of a license for a cause related to operation of a motor vehicle while intoxicated. This section does not require a criminal conviction. If the administrative suspension is a "motor vehicle action" then it is reportable under FAR 61.15(e). A single motor vehicle action does not carry adverse consequences, but under FAR 61.15(d), two motor vehicle actions within a 3-year period establishes a basis for adverse action.
I hope this information is helpful.
Sincerely,
Richard D.
McCurdy Attorney
Regulations Referenced
Snapshot retrieved August 6, 2026.