9/4/2010Missouri: Federal Judge Likes Red Light Cameras, Denies Class Action Refund
Federal judge who likes red light cameras allows Springfield, Missouri to escape refunds for illegal program.
Fighting speed camera and red light camera tickets in federal court is becoming increasingly difficult as yet another US district court judge yesterday embraced the use of automated ticketing machines. Judge Nanette K. Laughrey dismissed the class action lawsuit that Gregory Mills had filed against the city of Springfield and Lasercraft, a private vendor that has since been bought out by American Traffic Solutions. Mills argued that because the Missouri Supreme Court in March struck down the city's program as illegal (view decision), those who received tickets were entitled to a refund.
Under the program, Lasercraft mailed tickets to the owners of vehicles who in many cases were not behind the wheel at the time of the offense and consequently had not violated any law. The suit argued that these individuals were denied a meaningful right to contest the $100 punishment imposed because challenges to the citation were heard not in a court with constitutional protections, but in an administrative hearing operated by an employee of the city that receives the proceeds from payment of any fines. Judge Laughrey dismissed the notion that anyone could be wrongly accused and assumed anyone mailed a ticket by Lasercraft was a scofflaw who should not have been running red lights.
"The freedom to run a red light is not a fundamental right that is deeply rooted in this nation's history and tradition," Laughrey wrote. "Under the lenient rational basis test, the city of Springfield's red light camera ordinance is rationally related to the legitimate government interest in public safety. Clearly, a legislative body could find that improved surveillance and enforcement of red light violations would result in fewer accidents."
Laughrey went on to insist the fine imposed was not a punishment and the mere declaration by Springfield city leaders that the program was "civil" deprived ticket recipients of any meaningful constitutional protection.
"The court finds that a mere $100 fine does not rise to the level of an intent to punish," Laughrey wrote. "As a civil ordinance, Section 106-161 need not provide the heightened procedural protections required by the Fifth, Sixth, and Eighth Amendments of the U.S. Constitution."
Laughrey finally ruled that the fact that the Missouri Supreme Court ruled Springfield's program was illegal did not affect her analysis under federal law.
"The due process clause does not require a state to implement its own laws correctly, nor does the Constitution insist that a local government be correct in its interpretation of what is permissible under state law," Laughrey wrote. "Thus, plaintiffs' attempt to convert violations of state law into federal due process claims improperly bootstraps state law into the U.S. Constitution. It is implausible that Section 106-161 could have denied plaintiffs substantive due process."
Cases against Springfield are pending in state courts. A copy of the federal decision is available in a 125k PDF file at the source link below.