Farley v. State, S00A0536.
| Decision Date | 30 May 2000 |
| Docket Number | No. S00A0536.,S00A0536. |
| Citation | 531 S.E.2d 100,272 Ga. 432 |
| Parties | FARLEY v. The STATE. |
| Court | Georgia Supreme Court |
OPINION TEXT STARTS HERE
Benson, Phillips & Hoffman, Jason K. Hoffman, Tifton, for appellant.
C. Paul Bowden, District Attorney, Holli G. Martin, Assistant District Attorney, Thurbert E. Baker, Attorney General, Andrea S. Hirsch, Christopher S. Brasher, Assistant Attorneys General, for appellee.
Rodney Fionn Farley was stopped while driving an automobile for failure to have his seat belt fastened, a violation of OCGA § 40-8-76.1.1 Cocaine was discovered during the traffic stop, and Farley was arrested. He filed a motion to suppress the evidence found in the search, contending that OCGA § 40-8-76.1 is unconstitutional because it denied him equal protection in that similarly situated adult drivers in pickup trucks are not subject to the seat belt requirement. At the hearing on the motion, Farley introduced evidence regarding the relative injury rates in passenger vehicle and pickup truck accidents. The trial court denied the motion, but granted a certificate of immediate review. This Court granted Farley's application for interlocutory appeal and directed the parties to address the question whether the trial court was correct in denying the motion to suppress on the ground that OCGA § 40-8-76.1 is not an unconstitutional denial of equal protection.
[Cit.]
Reed v. State, 264 Ga. 466, 467, 448 S.E.2d 189 (1994). For the purpose of this appeal, we will assume that Farley has borne the burden of showing that occupants of passenger vehicles and adult occupants of pickup trucks are similarly situated with regard to the subject matter of the legislation at issue. The remaining burden for Farley to bear is to show there to be no rational relation between the classification at issue and the purpose of the legislation.
We agree with the parties that because the classification in this appeal involves neither a suspect class nor the exercise of a fundamental right, we must examine it under the "rational basis" test. City of Atlanta v. Watson, 267 Ga. 185(1), 475 S.E.2d 896 (1996). "Under the rational basis test, a legislative classification does not deny equal protection if the classification bears a direct relation to the purpose of the legislation." Love v. State, 271 Ga. 398(3), 517 S.E.2d 53 (1999).
It is readily apparent that public safety is the purpose of the statute. The question for decision, therefore, is whether the challenged classification bears a direct relation to the goal of advancing public safety. The evidence Farley presented to the trial court established that accidents involving passenger vehicles are much more numerous than those involving pickup trucks, and that approximately three times as many fatalities occurred in passenger vehicle accidents when seat belts were not worn than when they were. Given those facts, we conclude that it is clear beyond argument that requiring persons occupying passenger vehicles to wear seat belts bears a direct relation to the goal of improving public safety.
Farley insists that because his evidence showed that occupants of pickup trucks are more susceptible to injury in the event of an accident than are occupants of passenger cars, OCGA § 40-8-76.1 cannot be considered to have a rational relation to the goal of improving public safety unless all persons occupying pickup trucks are also required to use seat belts. That "all or nothing" approach, which questions the wisdom of the legislature's action, conflicts with established principles of constitutional law.
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