The aviation regulatory copilot.
Defensible citations only.

Generally yes — if the descent to circling minimums (MDA) is conducted under actual or simulated instrument conditions.

14 CFR §61.57(c) requires six instrument approaches “performed and logged” within the preceding six calendar months, under “actual or simulated instrument flight conditions.”

The FAA Chief Counsel addressed circle-to-land in the Hicks (2011) Legal Interpretation: the instrument-approach segment must be flown in actual or simulated IMC, but the circling maneuver itself does not require IMC. Once you've descended to MDA in instrument conditions, the approach counts.

• Counts: IMC descent to MDA, then circle in VMC after breakout; simulated instrument (hooded) all the way to MDA
• Does not count: cancelling IFR before the approach; flying the entire approach in VMC

Sources14 CFR §61.57(c); FAA Chief Counsel Hicks Letter (Sept 2011).

14 CFR §91.13(a): “No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.”

How it's used: §91.13 is typically paired with a more specific underlying violation as a blanket catch-all. Common pairings: low-altitude (§91.119), VFR-into-IMC (§91.155, §91.157), aerobatic (§91.303), runway incursions.

Standard for violation: NTSB precedent (Administrator v. Roach, 2005) requires showing actual or potential endangerment of another — not just a technical violation. Self-endangerment alone is generally insufficient under §91.13(a).

LOI response framework (FAA Order 2150.3): ten-day response window; do not admit; engage counsel; defense frequently turns on the absence of actual endangerment to third parties.

Sources14 CFR §91.13(a); Administrator v. Roach, NTSB Order EA-5180 (2005); FAA Order 2150.3.

No. A Sport Pilot may not act as PIC at night under any conditions.

14 CFR §61.315(c)(5) prohibits a Sport Pilot from acting as PIC of a light-sport aircraft at night. This restriction is absolute — no endorsement removes it. To act as PIC at night, the pilot must hold at minimum a Private Pilot certificate.

“Night” is defined in 14 CFR §1.1 as the period between the end of evening civil twilight and the beginning of morning civil twilight (per the Air Almanac, converted to local time).

Other Sport Pilot restrictions (§61.315(c)): no Class A airspace; Class B/C/D requires endorsement; above 10,000 ft MSL or 2,000 AGL (whichever is higher) prohibited; visibility <3 SM prohibited; no operation without visual surface reference.

Sources14 CFR §61.315(c)(5); 14 CFR §1.1.