Are there audits or FOIA/CPRA requests showing exact CDL counts for undocumented holders in California and New York (by year)?
Executive summary
Requests and audits do exist that quantify non‑domiciled or potentially undocumented Commercial Driver’s Licenses (CDLs), but the public record is fragmented: federal FMCSA sampling found California had roughly 62,000 unexpired non‑domiciled CDLs with a sampled failure rate of about 26% — extrapolated to roughly 16–17,000 non‑compliant records that were later cancelled [1] [2]. New York and other states appear in enforcement actions and arrests, but publicly available reporting in these results does not show a clean, year‑by‑year FOIA/CPRA table of “exact CDL counts for undocumented holders” by year [3] [4] [5].
1. Audit headlines: FMCSA sampling in California produced headline numbers
A nationwide FMCSA audit sampled non‑domiciled CDL records and identified widespread problems; the sample in California suggested about 26% noncompliance among roughly 62,000 unexpired non‑domiciled CDLs, which FMCSA and USDOT have described as extrapolating to ~16–17,000 problematic licenses that were cancelled or placed under review [1] [2]. Federal statements set the frame: the DOT directed California to produce a full audit and issued notices to ~17,000 holders that their credentials would expire within 60 days [2] [1].
2. What those federal “non‑domiciled” figures mean — and what they do not
FMCSA’s term “non‑domiciled CDLs” refers to credentials issued to people who do not claim U.S. domicile and often includes lawful non‑immigrant visas or other specific categories; the audit measured regulatory compliance, not a tidy count of “undocumented” people [3] [6]. FMCSA sampling showed error rates (e.g., “one in four” in California) and specific monthly issuance spikes (3,820 non‑domiciled CDLs/CLPs in California in June 2025 in one cited sample), but available reports emphasize compliance failures rather than publishing year‑by‑year totals of CDLs held by people the federal government designates as undocumented [3].
3. New York: arrests and viral claims, but not a public year‑by‑year FOIL spreadsheet
Enforcement actions and media coverage show arrests of undocumented drivers holding state CDLs — for example, Operation Bear Cave and related actions led to arrests of 30 undocumented holders with CDLs from multiple states including New York [4]. High‑profile items like the “No Name Given” New York CDL produced political claims and fact‑checks: New York DMV says the image was authentic but “no name given” can reflect a single‑name holder, and Snopes and Times Union noted New York didn’t issue CDLs to undocumented people under its Green Light Law (which covers non‑commercial licenses) — again, these items document incidents, not an authoritative annual ledger of undocumented CDL holders [5] [7] [8].
4. Public‑records routes exist but the record is incomplete in reporting
Both California and New York have public‑records processes (California CPRA/CPRA FAQs; New York FOIL/OpenRecords tools) that can be used to seek counts or audit materials, and the federal DOT and FMCSA have issued audit letters and press materials summarizing findings [9] [10] [2]. But the sources collected here show agencies publishing sampled audit results, press releases and notices, not comprehensive, year‑by‑year FOIA/FOIL/CPRA disclosures listing exact counts of CDLs held by “undocumented” individuals by calendar year [2] [1] [9].
5. Why year‑by‑year “exact counts” are hard to produce from current materials
States and federal agencies use differing definitions (non‑domiciled vs. undocumented vs. visa status categories), privacy protections (New York’s Green Light Law restricts data sharing), and sampling methods; FMCSA’s publicly cited numbers are extrapolations from samples, not raw, unredacted line‑item year tables made publicized in these sources [3] [8] [6]. Several outlets note agencies “don’t keep records” in the way advocates want or that data are redacted or protected, and CPRA/FOIL/FOIA processes can yield records but face exemptions, redactions and litigation [11] [9] [12].
6. Competing narratives and political uses of the data
Federal DOT and DHS officials have framed the audits as evidence of dangerous noncompliance and used sampling to justify new, stricter federal rules and immediate revocations in California; state DMVs and some reporting point to lower crash rates among California CDL holders and procedural complexities, producing conflicting emphasis in coverage [6] [13]. Political actors have amplified anecdotes (e.g., “No Name Given” license) into broad claims about policy failure; fact‑checks and DMV statements counter some viral assertions [5] [7].
7. Practical next steps for a thorough year‑by‑year count
Available sources show two realistic paths: file targeted FOIL/FOIA or CPRA requests with the state DMV asking for audited, redacted tables of non‑domiciled CDL counts by issuance year and by disposition (and be prepared for privacy redactions and extensions) [9] [14]; request FMCSA’s full audit datasets or methodology memos via federal FOIA to obtain the sampling frame and extrapolation logic that produced the 26%/17,000 figure [3] [2]. Current reporting documents the audits and enforcement actions but does not publish a clean, public year‑by‑year roster of “undocumented CDL holders” in the two states [1] [4].
Limitations and transparency note: this analysis cites only the reports and public statements supplied above and therefore cannot confirm the existence of any specific year‑by‑year FOIA/CPRA release not referenced in those sources; requests via FOIA/CPRA or federal FOIA are the established route to attempt to obtain such a dataset [9] [14].