MEMORANDUM DECISION and ORDER I. INTRODUCTION On May 15, 2019, pro se plaintiff John Joseph Forjone (“Forjone” or “plaintiff”) filed this civil action against defendants the State of New York Department of Motor Vehicles (“NYS DMV”), the State of New York Office of Children and Family Services (“NYS OFS”), the Warren County Department of Motor Vehicles (“Warren County DMV”), the Warren County Department of Social Services (“Warren County DSS”), the Orleans County Department of Social Services (“Orleans County DSS”), the Secretary of the United States Department of Homeland Security (the “DHS Secretary”), and the Secretary of the United States Department of Transportation (the “DoT Secretary”). Broadly stated, Forjone’s pleading1 alleges that the state and federal agencies named as defendants have violated his federal civil rights by repeatedly denying his request to renew his New York State commercial driver’s license, which expired several years ago. There are three motions pending: first, the NYS DMV and the NYS OFS (collectively the “State defendants”) have moved under Federal Rule of Civil Procedure (“Rule”) 12(b)(1) and (6) to dismiss Forjone’s complaint in its entirety; second, plaintiff has cross-moved for injunctive relief against the “constitutionally questionable Green Light Law”; and third, the DHS Secretary and the DoT Secretary (collectively the “Federal defendants”) have moved under Rule 12(b)(1) and (6) to dismiss plaintiff’s complaint to the extent it asserts any cognizable claims against them. Dkt. Nos. 9, 15, 16. The motions have been fully briefed2 and will be decided on the basis of the submissions without oral argument. II. BACKGROUND The following facts are taken from Forjone’s complaint, Dkt. No. 1, and the attached exhibits, Dkt. No. 1-2, and are assumed true for the purpose of resolving the motions to dismiss. On January 5, 2004, the NYS DMV issued Forjone, a resident of Lake Luzerne, New York, a commercial driver’s license (“CDL”), a special type of license required to operate large or heavy vehicles like tow trucks, tractor trailers, and buses. Compl.
1, 9 & Ex. A to Compl.; see also Commercial Driver Licenses, DEPARTMENT OF MOTOR VEHICLES, https://dmv.ny.gov/commercial-drivers/commercial-driver-licenses (last visited Oct. 29, 2019). Until it expired on October 15, 2009, Forjone enjoyed an “unblemished” safety record and earned “$50,000 per year” driving with his NYS DMV-issued CDL. Compl.
