Fowler v. Benson

Plaintiffs challenged Michigan’s practice of suspending drivers' licenses for unpaid court fees, as applied to indigent drivers, under 42 U.S.C. 1983. Plaintiffs argued that practice is irrational because license suspension made their commuting to work much harder, reducing the chances that they will pay the debt, and made it difficult to attend medical appointments. The district court enjoined the enforcement of the law. The Sixth Circuit reversed. The mere fact that a driver has a Fourteenth Amendment property interest in his license does not answer the more particular question of whether Michigan law creates the specific property entitlement Plaintiffs claimed. Michigan’s statutory scheme for license suspension makes no reference to the indigency status of those whose licenses are subject to suspension. If Plaintiffs’ indigency is not relevant to the state’s underlying decision to suspend their licenses, then providing a hearing where they could raise their indigency would be pointless and do nothing to prevent the “the risk of erroneous deprivation.” The state has a general interest in compliance with traffic laws. By imposing greater consequences for violating traffic laws, the state increases deterrence for would-be violators. The state also has legitimate interests in promoting compliance with court orders and in collecting traffic debt. View "Fowler v. Benson" on Justia Law