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.
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.
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.
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.
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.
Owners, dealers, lenders, insurers, repair shops, title companies, tax assessors, and families unite under a Texas nonprofit to challenge the rule.
Every date and citation below comes from the official rulemaking record. Sources are linked in Documents.
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.
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.
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.
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.
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.
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.
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.
Sign the Coalition Agreement and make your participation contribution. One-time or recurring options are available.
The Board manages communications with counsel and sets strategy across the membership.
Cobb & Gervasi files and prosecutes the case. You stay informed through CARS at every stage.
No settlement binds you without written consent. You receive at least 30 days to review any recommended offer, with full opt-out rights.
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.
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
Affected by the rule, or want to stand with the coalition? Tell us who you are and we'll keep you posted — and reach out when membership and the contribution form open.
We use your information only to contact you about the coalition. No spam; unsubscribe anytime.
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.
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.
Chair · Board of Directors
Director
Director
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.
“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
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.
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.
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.
Links open official government sources in a new tab. Provided for public information only; not legal advice.
If you don't see your question here, contact the Board — we'll get back to you within two business days.
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.
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.
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.
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.
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.
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.
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.