Missouri: Federal Judge Denies Red Light Camera Class Action Refund

The Newspaper
by The Newspaper

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.

Mills v. Springfield (US District Court, Western District of Missouri, 9/3/2010)

[Courtesy: Thenewspaper.com]

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  • Toxicroach Toxicroach on Sep 07, 2010

    Not every injustice should be in the federal courts. Sure, it sucks that those people got those tickets, and Missouri's decision that the procedure was illegal was correct. But do we really want class action lawsuits in federal court over municipal traffic ordinances? Because that was the door the plaintiffs were trying to open.

  • Henrythegearhead Henrythegearhead on Sep 07, 2010

    In some states the tickets are not civil/parking tickets. They are criminal infractions, and carry points which could cause you to lose your license. A real punishment. In those U.S. states (including California and Arizona and some other midwest or western states), the cameras are set up to get a "face photo" of the driver; This is done because criminal charges must always name the actual violator. In California, that need to identify the actual violator has led to the creation of a unique investigatory tool, the Snitch Ticket. When the police encounter a face photo which is clearly neither the registered owner nor another licensed driver residing at the owner's address, at least 38 California police departments mail the registered owner a document that looks like a real camera ticket (but in fact is not, and has no legal weight whatsoever), in an effort to fool the owner into responding (he does not have to) and identifying the driver responsible for the offense. If in doubt, Google the term Snitch Ticket.

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