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3/3/2010Missouri Supreme Court Strikes Down Red Light Cameras
Missouri Supreme Court strikes down the red light camera program run by city of Springfield.
The supreme court of Missouri sent photo enforcement companies scrambling on Monday after it declared the red light camera administrative hearing process in the city of Springfield to be void. The high court moved with unusual speed, handing down a strongly worded, unanimous decision about one month after hearing oral arguments in the case.
"This is a $100 case," Judge Michael A. Wolff wrote for the court. "But sometimes, it's not the money -- it's the principle."
At first glance, the court's decision appeared to be limited to a technical legal issue regarding Springfield's authority to adjudicate a photo ticket against motorist Adolph Belt in an administrative hearing. The court indicated that this was plainly not permitted under state law. Section 479.010 of the Missouri Code requires ordinance violations of this type to be heard in a circuit or municipal court. Springfield had argued that its administrative hearing officer was the first and last word on all judgments, with no appellate courts -- not even the supreme court itself -- having any jurisdiction over the matter.
A closer look at the ruling shows that the high court judges expressed a dim view toward the legal arguments often cited by municipalities to justify their red light cameras programs. For example, the court made it clear that no city had any authority to treat red light violations in the same manner as a parking ticket.
"The administrative system at issue here is created for a violation of a red light ordinance, which typically is considered a moving violation," Wolff wrote.
That means no city in Missouri, including Kansas City and St. Louis, has the authority to issue civil violations that carry no points. A footnote explained further that charter cities have no power to act in areas limited by state law. Both premises are key rebuttals to the argument that municipalities in the state have the authority to create red light camera programs without the sanction of state law. The high court also called into question Springfield's use of short yellows.
"Undeniably a traffic expert, Belt timed the yellow caution light at the intersection and found that it was rather quick," Wolff wrote. "He also concluded that the stoplight and the cameras needed to be synchronized."
Another footnote cited three articles by TheNewspaper that Belt had brought to the court's attention.
"Another article he found stated that a study in Texas had found that adding an additional second to yellow lights corresponded to a 40-percent reduction in crashes [view study]," Wolff wrote. "Even so, the city of Springfield had chosen to reduce its yellow-light timing at more than 100 intersections prior to starting red light camera ticketing [view article]."
State supreme courts are now evenly split on the issue of photo enforcement. Missouri's supreme court joined the Minnesota high court which struck down red light cameras as illegal in 2007, explaining that cities may not water down the due process protections of motorists simply for the ease of issuing tickets (view ruling). On the other hand, the Ohio Supreme Court (read opinion) and Iowa Supreme Court (read opinion) declared camera use consistent with state laws.
The Missouri Supreme Court judges voided Belt's citation without remanding proceedings to a lower court. A copy of the decision is available in a 50k PDF file at the source link below.
Source: Missouri v. Belt (Supreme Court of Missouri, 3/2/2010)
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