Stinnie v. Holcomb
| Decision Date | 13 March 2017 |
| Docket Number | CASE NO. 3:16-cv-00044 |
| Parties | DAMIAN STINNIE, ET AL., Plaintiffs, v. RICHARD D. HOLCOMB, IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF THE VIRGINIA DEPARTMENT OF MOTOR VEHICLES, Defendant. |
| Court | U.S. District Court — Western District of Virginia |
Damian Stinnie owes fees, fines, and costs to Virginia's courts. He cannot pay them, so Virginia law requires that his driver's license be suspended until he pays. But the suspension makes it difficult to get and keep a job. In other words, because he cannot pay the fees, his license is suspended, but because his license is suspended, he cannot pay the fees. Caught in this cycle, Stinnie and others have sued the Commissioner of Virginia's Department of Motor Vehicles ("DMV"). They argue that the Commissioner suspended their licenses and that those suspensions violated their federal constitutional rights to due process and equal protection.
Because jurisdiction is absent from the current iteration of this lawsuit, the Constitution prevents this Court from ruling on the substance of Plaintiffs' due process and equal protection challenges, however meritorious they may prove to be when decided in a proper forum.
First, Congress and the Constitution have not granted federal district courts the authority to hear appeals from state courts. The U.S. Supreme Court is the only federal court authorized to do so. Because this case involves allegedly unconstitutional suspension orders of Virginia state courts, Plaintiffs must seek relief from Virginia's appellate courts and ultimately the U.S. Supreme Court, not this Court.
Second, the Constitution empowers a federal court to hear a case only if the court could fix the harm plaintiffs allegedly suffered at the hands of the defendant. Here, because the state courts (not the Commissioner) suspended the licenses, the complained-of injury is not fairly traceable to the Commissioner and cannot be fixed by a court order against him.
Third, the Constitution's Eleventh Amendment forbids certain kinds of lawsuits in federal court against States. The Supreme Court has recognized, however, that the Eleventh Amendment does not prohibit lawsuits seeking to stop a state official from violating federal law. But this exception applies only when the state official has a special relationship to the supposedly unlawful conduct. Because that special relationship is absent here, the exception is inapplicable, and the Eleventh Amendment bars the case against the Commissioner.
This Court reiterates it is not deciding whether Virginia's license suspension scheme is unconstitutional. All this Court is deciding (indeed, all it has the legal authority to decide) is that it lacks the lawful ability to rule on the merits of Plaintiffs' challenge, at least as this lawsuit is currently constituted. Thus, the Commissioner's motion to dismiss will be granted.
Part I of this Opinion explains the standard of review.
In Part II, the Court broadly outlines the allegations in Plaintiffs' Complaint.
Part III discusses the exact nature of Plaintiffs' constitutional challenge. Plaintiffs make clear that they challenge their license suspensions issued (in their view) by the Commissioner pursuant to Va. Code § 46.2-395(B).
Next, Part IV analyzes the text, structure, and meaning of § 46.2-395. This analysis reveals that a suspension under § 46.2-395 is done by the state court, not the Commissioner, for failure to pay court costs and fines.
Part V explains that this case is barred from federal district court by the Rooker-Feldman doctrine. Generally speaking, that doctrine holds that federal courts (other than the Supreme Court) cannot hear challenges to state court orders, like those at issue here.
In Part VI, the Court concludes that Plaintiffs lack constitutional standing in this case to challenge their suspensions. The harm they complain of (unconstitutional license suspensions) was not caused by the Commissioner. Ordering the Commissioner to "reinstate" the licenses would neither be related to the constitutional violation nor remedy the underlying suspensions.
Part VII finds that the Commissioner is not sufficiently responsible for and associated with the suspensions, and as such he is entitled to Eleventh Amendment immunity.
Finally, Part VIII notes other jurisdictional issues.
The Commissioner argues that the Complaint fails to allege a claim for relief. Under the associated standard, the Court assumes the truth of the Complaint's factual allegations and draws reasonable inferences in Plaintiffs' favor, but it does not adhere to the Complaint's legal conclusions, unadorned labels, conclusory statements, and formulaic recitation of the elements. See Ashcroft v. Iqbal, 556 U.S. 662, 678, 680-81 (2009). The Court may consider attachments to the Complaint. Leichling v. Honeywell Int'l, Inc., 842 F.3d 848, 851 (4th Cir. 2016).
The Commissioner, though, also seeks dismissal for lack of jurisdiction. He does not specify whether he mounts a "facial" challenge to the Complaint or a "factual" one based on additional evidence. As his only submissions were judicially noticeable state court orders (dkts. 10-1, 30-1) and the parties did not seek an evidentiary hearing, the Court concludes it is a facial one. See 24th Senatorial Dist. Republican Comm. v. Alcorn, 820 F.3d 624, 629 (4th Cir. 2016) (). Accordingly, the Court applies thefamiliar Twombly/Iqbal standard, taking care not to accord the "presumption of truth to conclusory statements and legal conclusions contained in [the] complaint." Beck v. McDonald, No. 15-1395, -- F.3d --, 2017 WL 477781, at *4 (4th Cir. Feb. 6, 2017). Importantly, this rule applies even when legal conclusions are couched as factual allegations. Papasan v. Allain, 478 U.S. 265, 286 (1986); SD3, LLC v. Black & Decker, Inc., 801 F.3d 412, 422 (4th Cir. 2015).1
Plaintiffs Damian Stinnie, Demetrice Moore, Robert Taylor, and Neil Russo are indigent Virginians who have suspended driver's licenses "for failure to pay court costs and fines that they could not afford." (Complaint ¶ 1). They allege that their suspensions were "automatic and mandatory upon default." (Id. ¶ 4). They request declaratory and injunctive relief against the Commissioner to:
address and remedy the systemic, pervasive, and ongoing failure of the Commonwealth to provide basic protections afforded by the Due Process and Equal Protection Clauses of the United States Constitution before taking the harsh enforcement measure of suspending driver's licenses against indigent people whose poverty prevents them from paying debts owed to courts.
(Id. ¶ 6). Plaintiffs "seek to represent a class consisting of all persons whose Virginia's driver's licenses are suspended due to unpaid court debt and who, at the time of the suspension, were not able to pay due to their financial circumstances." (Id. ¶ 373 (emphasis added)).
They contend that "DMV is the entity responsible for the issuance, suspension, and revocation of driver's licenses."2 (Complaint ¶ 22). A driver's license is critical for life functions such as employment, education, and family care. (Id. ¶¶ 30-31). In recent years, hundreds of thousands of Virginians allegedly have had their licenses suspended for failure to pay court costs and fines. (Id. ¶¶ 32-33). Such suspensions "can trap the poor in an impossible situation: inability to reinstate their licenses without gainful employment, yet inability to work without a license." (Id. ¶ 34).
"Plaintiffs' licenses," they claim, "were suspended by the Defendant3 immediately upon their default, without any inquiry into their individual financial circumstances, or the reasons underlying their failure to pay." (Complaint ¶ 39 (emphasis added)). They cannot enter into repayment installment plans, either because the state courts to which they own money do not have such plans or because they cannot afford the plans that are offered. (Id. ¶ 41).
Mr. Stinnie is the lead named plaintiff. He received four traffic citations in late 2012 or early 2013, three of which resulted in conviction and over $1,000 in fines and court costs. (Complaint ¶¶ 53-54, 57, 61). Earning only $300 per week, he was unable to pay off this debt, leading—according to him—the Commissioner to suspend his license on May 20, 2013, without assessing whether he had the ability to pay. (Id. ¶¶ 61-67). Stinnie was cited seven days later for driving on a suspended license. (See id. ¶ 68; Va. Code § 46.2-301). He was convicted ofthis offense on September 19, 2013, while still hospitalized for lymphoma. (Complaint ¶ 73). He incurred additional fines and court costs for that conviction, further hampering his financial situation, as did medical treatments he needed to fight lymphoma. (Id. ¶¶ 68-78).
This cycle repeated itself in 2016 when—after battling poor health, homelessness, and a dire financial situation—he received more fines and costs for reckless driving and driving on a suspended license. (Complaint ¶¶ 89-99). As of July 2016, Stinnie owed $1,531 in costs and fines to various state courts. (Id. ¶¶ 111-18). He cannot afford to pay this amount given his limited income and payments for his car, which doubles as shelter when he cannot procure housing. (See id. ¶¶ 105-10).
As for Plaintiffs Moore, Taylor, and Russo, their particular circumstances differ somewhat from Stinnie (e.g., their underlying charges of conviction, the severity of their indigency and causes thereof), but the basic pattern is the same. All were convicted of some traffic violation or crime, thus incurring court costs, fees, and fines they could not afford to pay.4 Their licenses were suspended as a result, frustrating their ability to provide for themselves and creating a risk of additional convictions if they drove in an effort to do so. (See Complaint ¶ 341)....
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