VFR weather minima

[poadeleted20]

We know you were in legal IFR but again, let's say simply for the sake of educational aviation discussion, that you WERE under legal scrutiny by the FAA, the local FSDO, and other legal powers and your strategy of silence in defence of your legal actions wasn't working for you in their pusuit of 91.13 against you.

Assumes facts not in evidence. I've never heard of the FAA charging anyone with 91.13 merely on the basis of the complaint of a non-pilot about an operation which was entirely within the bounds of normal IFR operations. IOW, you're asking what I'd do if the sun came up in the west -- no real answer for that.

But if it did come to that, I would ask them to describe their basis for saying the operation was "careless/reckless." Once they did that, I could form a defense strategy. However, I do not believe there is any way they could make the case in the first place. If you go through the cases where 91.13 is the only charge, you will invariably see behavior which is clearly contrary to safe operating procedure. The case you describe has no such content. Remember that the mandate to investigate all complaints for validity is not a mandate to file charges regardless of the validity of the complaint.