E-Alert Case Updates
United States District Court Finds that Speeding Citations Issued to Plaintiffs Caught on Speed Cameras do not Infringe Upon the Fourteenth Amendment’s Due Process Clause
Snider International Corp. v. Town of Forest Heights
In Snider International Corp. v. Town of Forest Heights, the United States District Court for the District of Maryland granted summary judgment for two Maryland towns, Forest Heights and Riverdale Park (“Defendants”), with respect to alleged due process violations arising from the use of automated speed monitoring systems (“speed cameras”). Snider International Corporation, Mark Cranford, Stan Derwin Brown, and Al Goyburu brought a putative class action suit against Defendants, asserting various violations of due process on behalf of four (4) classes of similarly situated individuals that had received speeding citations (“Plaintiffs”). In reaching its decision, the Court found that only those plaintiffs who had paid their citations maintained cognizable claims, while defaulting plaintiffs did not. The Court ultimately held that the citations did not violate the Due Process Clause of the Fourteenth Amendment, and therefore granted summary judgment for Defendants.
Between March and December 2011, Plaintiffs received fifty-five (55) citations issued by Defendants for speeding in various school zones. Plaintiffs filed this putative class action and sought certification on April 24, 2012. One group of plaintiffs paid their citations upon receipt. A second group of plaintiffs did not contest liability, but nevertheless refused to pay their citations. A third group of plaintiffs challenged the citations in the Maryland District Court and lost, but refused to pay. The District Court entered default judgments against any plaintiff who refused to pay. Plaintiffs identified themselves in four (4) classes, depending on the municipality that issued the citation, and whether the individual plaintiff had paid: Forest Heights Paid Class, Forest Heights Default Class, Riverdale Park Paid Class, and Riverdale Park Default Class.
Plaintiffs’ complaint alleged numerous claims under 42 USC § 1983 for violations of their rights under the Due Process Clause of the United State Constitution and Article 24 of the Maryland Declaration of Rights. First, Plaintiffs argued that Defendants did not comply with the informational requirements set forth in MD. CODE ANN., TRANSP. § 21-809. In particular, Plaintiffs argued that the law required the citations to include a sworn certificate notifying recipients of certain statutory requirements imposed on Defendants, and affirming that each of those requirements had be satisfied. Second, Plaintiffs alleged that Defendants violated Plaintiffs’ rights to due process when entering the citations into evidence despite the citations’ non-compliance with § 21-809. Third, given that the state court had entered judgment against Plaintiffs on the basis of the deficient citation, Plaintiffs alleged that their due process rights were violated when Defendants secured judgments against them without satisfying their burden of establishing each element of the violation at trial. Fourth, Plaintiffs claimed that their due process rights were violated because the citations were electronically signed and therefore not sworn affidavits. Finally, Plaintiffs alleged that Defendants violated Plaintiffs’ due process rights when serving the citations by first-class mail. Plaintiffs sought damages commensurate with the total amount of citations, costs incurred in the district court, attorneys’ fees, and all other remedies that equitably flowed from deprivation of due process. Defendants moved to dismiss Plaintiffs’ action or, in the alternative, for summary judgment. Defendants raised jurisdictional arguments with regards to lack of standing and the Rooker-Feldman doctrine, sufficiency arguments for Plaintiffs’ failure to state a claim, and affirmative defenses of res judicata and waiver of claim.
The United State District Court for the District of Maryland entered summary judgment in favor of Defendants. The Court treated Defendants’ motion as one for summary judgment because the facts in the complaint were insufficient to consider Defendants’ affirmative defenses on the pleadings alone. Given that Plaintiffs did not seek discovery in this case, the Court found summary judgment appropriate. The Court found that the Riverside and Forest Heights Defaulting Classes failed to state a cognizable claim, but that the Riverside and Forest Heights Paid Classes were not barred from bringing their claims. With respect to standing, the Court found it sufficient that Plaintiffs alleged deprivation of due process as injury. However, claims by Defaulting Classes could not survive Defendants’ res judicata defense because, in seeking the exact same damages required to satisfy their outstanding judgments, defaulting plaintiffs sought to effectively accomplish the same result as either overturning or vacating the state court’s entry of default judgment. Because the Defaulting Classes sought to effectively nullify the state court’s judgment, and those plaintiffs could have brought their § 1983 claim as a counterclaim at the state level, this action in federal court was identical to that adjudicated at the state level. Therefore, members of the plaintiff class that received default judgments (1) were the same parties as in the state court decision, (2) presented an identical action arising out of the same set of operative facts, and (3) the state court had entered a final judgment on the merits. Contrastingly, the Forest Heights Paid and Riverdale Park Paid Classes were not precluded because the state court never entered final judgment on the merits.
The Court rejected Defendants’ jurisdictional defense under the Rooker-Feldman doctrine. The Rooker-Feldman doctrine is derived from Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983), in which the Supreme Court found that lower federal courts do not have jurisdiction to review state court judgments. The Court found that Rooker-Feldman only barred collateral attacks where plaintiffs sought to reverse or modify state court judgments, rather than divest the federal courts of subject matter jurisdiction to adjudicate a previously litigated matter. The Court cited Exxon and Davani v. Va. Dep’t of Transp., 434 F.3d 712 (4th Cir. 2006) for the proposition that Rooker-Feldman had been limited in application to only those suits seeking direct review of state court judgments; in other words, a federal court must examine whether the state court loser seeks to redress an injury caused by the state court itself. In this case, Plaintiffs sought redress for injuries that occurred when Defendants violated their procedural due process rights, rather than review the state court’s judgments directly. Hence, the Rooker-Feldman doctrine did not apply.
Similarly, the Court found that Plaintiffs who paid their citations did not waive their right to seek damages. Defendants argued that the citations disclaimer, stating that “PAYMENT OF THE PENALTY AMOUNT FOR THE VIOLATION IS AN ADMISSION OF LIABILITY,” Snider Int’l Corp. v. Town of Forest Heights, No. 12-1248, slip op. at 14 (D.Md Nov. 29, 2012), served to waive Plaintiffs’ claims, similar to a settlement agreement or consent decree. However, the Court noted that the disclaimer was not an agreement between the parties, and Plaintiffs did not desire to admit liability. The Court found that Plaintiffs did not dispute that they violated the law, but rather that Plaintiffs’ constitutional rights were infringed. Therefore, Defendants’ waiver argument was inapplicable.
Ultimately, the Court granted summary judgment to Defendants because Plaintiffs failed to state a meritorious § 1983 claim. Though the Court found the Defaulting Classes claims precluded, the Court examined the merits of all claims in the putative class. The Court noted that 42 USC § 1983 does not create substantive rights, but rather provides “a method for vindicating federal constitutional or statutory rights.” Snider Int’l Corp., slip op. at 22. Hence, Plaintiffs could not allege violations of due process as guaranteed by the Maryland Declaration of rights because §1983 creates a cause of action for a violation of federal rights only. The Court examined both the procedural and substantive components of Plaintiff’s due process claims under the Fourteenth Amendment. Procedurally, the Court found that Plaintiffs were provided notice and an opportunity to be heard; those who declined to avail themselves of this opportunity suffered no injury and failed to state a cognizable claim. Furthermore, those plaintiffs who did appear in the district court received adequate process. Though the Court found that Plaintiffs’ property interests were significant, it held that the Plaintiffs’ interests were outweighed by Defendants’ interest in efficient enforcement of their traffic laws. The Court rejected Plaintiffs’ contention that the use of electronic signatures deprived the citations of legal effect. Substantively, the Court held that Plaintiffs’ injuries could be avoided by adequate pre-deprivation protections or post-deprivation remedies because Plaintiffs were permitted to stand trial and raise the same arguments at the state level as was brought before the Federal District Court in this case. Therefore, the state’s treatment of Plaintiffs was neither arbitrary nor irrational. Because Plaintiffs’ due process claim were without merit, the Court entered summary judgment in favor of Defendants.
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