FMCSA Adjudicated 10 Chameleon Carrier Cases in 3 Weeks. The Last Moving Case Was 4 Years Ago.

FMCSA maintains an adjudication system at fmcsa.dot.gov/regulations/adjudication-decisions. It publishes formal orders on applications, appeals, petitions, record consolidations, and out-of-service reviews. The system is searchable by case name, docket number, and document content.

Between August 21 and September 4, 2026, the system posted 10 decisions. Record consolidation orders. Rejection appeals. Interim orders. Procedural orders. Binding arbitration referrals. The system is active. It is staffed. It is producing decisions.

None of the 10 involved household goods.

A search for 'household goods' returns results going back to 2019. The most recent household goods adjudication decision was posted July 21, 2022, over four years ago: AAA Auto Transport, Inc., L3 Trucking, LLC, and L3 Transportation, LLC (FMCSA-2022-0138), a record consolidation order. Before that, the last was March 2020: Tana Movers & Storage (FMCSA-2019-0126).

The adjudication system works. It just does not work for household goods cases.

On September 4, 2026, FMCSA posted a Final Order in the matter of 3 Logistics Company LLC (FMCSA-2026-1226, USDOT 3919482). The order is 16 pages with 30 footnotes. It is a textbook example of FMCSA catching and blocking a chameleon carrier reincarnation.

The facts: James Jones owned Relentless Trucking Logistics LLC (USDOT 3918903), a motor property carrier. In June 2023, FMCSA conducted an on-site compliance review. Relentless received a proposed Unsatisfactory safety rating. Jones did not seek an upgrade or submit a corrective action plan. The Unsatisfactory rating took effect August 5, 2023. FMCSA issued an Order to Cease All Transportation the same day.

Relentless operated anyway. On December 20, 2023, FMCSA caught the carrier operating in interstate commerce while under an out-of-service order. A $10,440 civil penalty was proposed. Relentless did not respond. FMCSA issued a Notice of Default and Final Agency Order requiring payment. Relentless did not pay. A second Order to Cease was issued December 9, 2024.

Meanwhile, Jones was a 25% member of 3 Logistics Company LLC. He executed a 'Member Withdrawal and Release Agreement' on July 8, 2024. On January 12, 2026, the remaining owner (Paris Johns) filed an application for reinstatement of 3 Logistics' operating authority. On the application's affiliate disclosure question, 'Do you currently have, or have you had within the last three years, relationships involving common stock, common ownership, common management, common control or familial relationships with any FMCSA-regulated entities?' the applicant answered 'No.'

FMCSA caught the lie. The Office of Registration found that Jones had signed 3 Logistics' MCS-150 as owner just 10 months before the 'withdrawal.' Jones paid the January 2026 application filing fee with his personal credit card. His billing address was the business and mailing address for both 3 Logistics and Relentless Trucking. The Office rejected the application on April 16, 2026.

The 3 Logistics decision rests on two statutory provisions and one policy:

49 U.S.C. 13902(a)(1)(C): An applicant for operating authority must disclose any relationship involving common ownership, common management, common control, or common familial relationship with any other motor carrier within the three-year period preceding the application date.

49 U.S.C. 13905(d)(2)(D): FMCSA may withhold, suspend, amend, or revoke registration if the carrier does not disclose a required relationship.

FMCSA Policy on Granting, Withholding, Suspending, Amending or Revoking Operating Authority Registration (77 Fed. Reg. 46147, August 2, 2012): 'The practice of reincarnating to avoid regulatory requirements and evade enforcement... demonstrates an inability and unwillingness to comply with applicable statutory and regulatory requirements.'

The Agency Decisionmaker applied these tools methodically. The three-year lookback caught Jones despite his withdrawal 18 months before the application. The credit card payment, shared address, and MCS-150 signature established continuing involvement despite the paper withdrawal. The Decisionmaker found it 'more likely than not' that common management existed based on Jones operating Relentless, managing its safety, representing it at the compliance review, signing 3 Logistics' MCS-150 as owner, and paying the application fee.

The decision also cites StealthX Transport LLC (FMCSA-2026-0662-0007, May 8, 2026) as parallel precedent: another carrier blocked for signing MCS-150 forms and holding authority as an officer while denying the affiliate relationship.

The framework is not theoretical. It is being applied, in 2026, with 16-page decisions and 30 footnotes, to general freight carriers.

The last 10 household goods adjudication decisions on FMCSA's system:

1. AAA Auto Transport / L3 Trucking / L3 Transportation: Record consolidation order (July 21, 2022) 2. Tana Movers & Storage: Final order on submission of evidence (March 3, 2020) 3. Moving Express & Storage: Order approving settlement (July 24, 2019) 4. Countrywide Asset & Auto Recovery (CAAR): Order denying petition for reconsideration (June 5, 2019) 5. Riojas / Four Star Trucking / 7 Star Transport: Order dismissing charges for lack of jurisdiction (May 10, 2019) 6. Seal Van Lines: Order approving settlement (May 8, 2019) 7. Low Price Mover dba News Van Lines: Final order (March 4, 2019) 8. Tiffin Athletic Mats: Final order on submission of evidence (February 15, 2019) 9. Jeff Hackett & Associates: Final order of default (January 9, 2019) 10. Call Me Van Line dba A City Van Line: Final order (January 7, 2019)

Seven of the ten are from 2019. One from 2020. One from 2022. Zero from 2023, 2024, 2025, or 2026.

During those four years of HHG adjudication silence, FMCSA's complaint database received approximately 15,000 household goods complaints. Trunk documents 404 complaints against Safe Ship, 290 against Menards, 229 against Coastal, 166 against Howards Vanlines. Handle With Care Moving was revoked and reincarnated as JCS Moving and Storage, accumulating 47 complaints in four months. A retired transportation attorney submitted two formal enforcement requests documenting the HWC-to-JCS reincarnation with entity links, shared principals, and complaint data.

The adjudication system did not produce a single HHG decision during this period.

3 Logistics Company LLC: A general freight carrier with an Unsatisfactory safety rating, a $10,440 penalty, and an OOS violation. FMCSA investigated, rejected the reincarnation application, defended the rejection on appeal with an 18-page evidence submission citing 13 exhibits, and the Agency Decisionmaker issued a 16-page final order upholding the rejection. Total elapsed time from application to final order: approximately 8 months.

Handle With Care Moving to JCS Moving and Storage: A household goods carrier revoked three times, reincarnated under the same operator (Levi Hasut), accumulating 47 consumer complaints in four months. Two formal enforcement requests submitted by a retired transportation attorney. Result: no adjudication proceeding initiated. No record consolidation order. No application rejection. JCS continues to operate.

The legal tools are the same. The three-year lookback applies. The 2012 reincarnation policy applies. The affiliate disclosure requirement applies. The adjudication system is active and staffed. The difference is that FMCSA uses these tools for freight carriers and does not use them for household goods carriers.

The Riojas case (FMCSA-2012-0174) from the HHG search results is itself instructive. That case, involving Four Star Trucking and 7 Star Transport (a documented HHG chameleon), was dismissed for lack of subject matter jurisdiction in May 2019. The Riojas decision helped establish the jurisdictional limits that made HHG enforcement harder. No subsequent HHG chameleon case has been brought to replace what Riojas took away.

FMCSA's adjudication decisions page includes a note: 'Only the 10 most recent documents meeting your search criteria may be displayed and successive searches may return no results due to search rate limits.'

The system is limited to 10 results per search. Successive searches are rate-limited. There is no bulk download. There is no API. The public cannot systematically review the adjudication record.

For general freight, this is an inconvenience. For household goods, it masks the absence. A researcher searching 'household goods' sees 10 results from 2019-2022 and might assume there are more. There are not. The 10 results are the complete visible record of HHG adjudication for the last seven years.

FMCSA publishes these decisions at regulations.gov. The docket numbers are public. The legal analysis is public. The evidence that the system works for freight is public. The absence of HHG decisions is also public. It is just harder to find.

The posting speed reveals who has access. Sue Lawless, FMCSA's former Assistant Administrator and Chief Safety Officer until July 2025, is now a partner at Scopelitis in Washington. In September 2026, she filed a petition on behalf of a CDL school revoked by the task force (FMCSA-2026-2938). It was posted to regulations.gov three days after filing. By contrast, a consumer complaint against an HHG broker (Griffin v. Menards, FMCSA-2026-2971) took months to appear. A retired transportation attorney's enforcement requests took 10 months. The system processes filings from former agency leadership in days. It processes filings from consumers and advocates in months. The access disparity is not hidden. It is measured in posting dates.