Opinion for the court filed by Circuit Judge HENDERSON.
KAREN LECRAFT HENDERSON, Circuit Judge.
The International Brotherhood of Teamsters (IBT) filed this action to challenge the "Legal Guidance on Criminal History Records Checks" (2004 Guidance) issued by the Transportation Security Administration (TSA) on May 28, 2004. The 2004 Guidance addresses what constitutes a "conviction" under TSA regulations, which prohibit airline and airport operators from employing...
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