What 391.15A means in plain language
FMCSR 391.15A prohibits operating a commercial motor vehicle when you are disqualified from doing so. Disqualification means your driving privileges for CMVs have been suspended, revoked, or cancelled by a state licensing authority, or you have been declared ineligible to hold a CDL due to medical, safety, or administrative reasons.
You cannot legally sit behind the wheel of a commercial truck while disqualified, regardless of whether you believe the disqualification is fair or temporary. This rule exists because disqualified drivers pose documented safety risks—they may have failed medical exams, accumulated too many violations, or been declared unsafe by regulatory action.
If you were cited for 391.15A at roadside, an inspector found evidence that you were operating a CMV while your CDL or CMV driving privileges were officially suspended or revoked.
What our enforcement data actually shows
Across our 13 million+ roadside inspection records, we have documented 3 all-time citations for 391.15A. In the last 12 months, we recorded 3 citations, with 0 citations in the last 90 days. This code ranks #2551 of 3,036 FMCSR codes by citation volume, making it among the least frequently cited violations in the database.
When 391.15A citations do occur, they carry serious consequences. Our data shows a 66.7% out-of-service rate—meaning two-thirds of drivers cited for this violation were immediately removed from service. This rate substantially exceeds the all-FMCSR average OOS rate of 31.4%, underscoring that inspectors treat disqualified-driver citations with high severity.
Of the 3 all-time citations in our records, 2 resulted in out-of-service placements and 1 did not. The most recent spike occurred in September 2025, when 2 citations were issued and 1 resulted in an OOS placement.
Who gets cited most
Our inspection records are too limited in volume (only 3 all-time citations) to identify clear geographic hotspots by state. However, our data does capture three carriers with documented citations: Christian A Canizales (USDOT 4259102), Garrido's Premier Trucking LLC (USDOT 4347482), and Blacktop Plus LLC (USDOT 4364179), each with 1 citation.
The vehicles cited included Freightliners (2 citations) and single instances of Ford, Meta, Ranc, and Rolr models. Because the absolute citation count is so low, vehicle-make patterns are not predictive.
How severe is this compared to similar codes
391.15A falls in the Driver Fitness category, alongside several peer violations related to CDL validity, medical certification, and driver qualification.
Compare 391.15A to related codes:
- 383.23(a)(2) — Operating a CMV with wrong CDL class: 50,385 citations, 98.4% OOS rate
- 383.23A2-LCDLN — Operating a CMV without a valid CDL: 47,123 citations, 98.6% OOS rate
- 391.41APC — Operating without a valid medical certificate in possession: 49,539 citations, 97.1% OOS rate
While these peer codes see tens of thousands of citations, 391.15A occurs rarely. However, when it does occur, the 66.7% OOS rate reflects that disqualification is treated as a serious, immediate safety concern. The data suggests that disqualification violations, though infrequent, are consistently enforced with high consequences.
How to avoid it
The most straightforward way to avoid 391.15A is to know your CDL status before every shift. Here are concrete steps:
- Check your CDL status regularly. Contact your state DMV or check your online driving record before each dispatch week. If you see a suspension notice, medical disqualification letter, or revocation order, do not operate a CMV until the disqualification is lifted.
- Respond to all medical re-certification requests on time. Many disqualifications stem from expired or missing medical certificates. If your state or FMCSA notifies you that your medical certificate is due or expired, obtain a valid certificate from an FMCSA-certified medical examiner and file it immediately.
- Track your violation history. Too many moving violations in a short period can trigger CDL suspension in many states. Know how many points or violations you have accumulated and how close you are to a suspension threshold.
- Do not drive if you receive a disqualification order. If you are notified by mail or email that your CMV driving privileges are suspended, revoked, or that you are medically unqualified, stop operating a CMV immediately. Driving while disqualified compounds the problem and triggers the high OOS rate we see in our data.
- Clarify disqualification status in writing. If you believe a disqualification was issued in error or if you have successfully appealed it, obtain written confirmation from your state DMV before returning to duty. A roadside inspector will check your record against the state licensing database—only a formal, documented reversal will clear you.
Because our records show only 3 all-time citations, this violation is rare. But the 66.7% OOS rate confirms that when it is cited, enforcement is immediate and severe. The simplest defense is to never drive while disqualified in the first place.