Very good point. Many aviators do not understand that what we colloquially call the "Federal Air Regulations" is really volume 14 of the Code of Federal Regulations. The process is administrative law, not civil or criminal. Completely different rules. The FAA staff that writes the violation is presumptively an expert and treated as such by the Administrative Law Judge. An offending pilot must provide factual evidence, such as ATC data, FAA approved operating limitations, or other "hard" information. Friends don't count.

Fly safe,

Wes
N78PS