924 F.3d 247
6th Cir.2019Background
- Plaintiffs Adrian Fowler and Kitia Harris are indigent Michigan residents whose driver’s licenses were suspended after failing to pay court-imposed fines/costs; they allege inability to pay and difficulty regaining or using licenses to work or obtain medical care.
- Plaintiffs brought a putative class action under 42 U.S.C. § 1983 seeking injunctive relief against Michigan Secretary of State Jocelyn Benson, arguing suspensions for nonpayment violate procedural due process and equal protection (wealth-based discrimination / extraordinary debt-collection).
- The district court granted a preliminary injunction requiring the Secretary to offer pre-suspension hearings on inability to pay, notice, and alternatives to full payment; the State appealed.
- The Sixth Circuit addressed jurisdictional challenges (standing, Rooker–Feldman, Pullman/Younger abstention) and found jurisdiction proper.
- On the merits the majority held Plaintiffs lack a protected entitlement—Michigan law does not create an indigency exception to suspension—so no procedural due process right to a pre-deprivation ‘‘ability to pay’’ hearing; equal protection challenges are reviewed under rational-basis scrutiny and fail.
- Judge Donald dissented, arguing (1) driver’s licenses are a protected property interest and (2) Mathews balancing requires pre-deprivation ability-to-pay hearings and reasonable alternatives for indigent drivers; she would have affirmed the injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural due process: is a pre-deprivation "ability-to-pay" hearing required before suspending a license for unpaid court debt? | Plaintiffs: license is a protected property interest; Michigan must provide pre-suspension hearing to contest indigency and alternatives. | Benson: Michigan law does not create an indigency entitlement; available post-deprivation or existing court procedures suffice; plaintiffs did not pursue them. | Majority: No protected entitlement to an indigency exception in Michigan law; therefore no due-process right to the requested pre-deprivation hearing; claim unlikely to succeed. |
| Equal protection: does suspending licenses for nonpayment of court debt impermissibly discriminate against the poor under Griffin/Bearden line? | Plaintiffs: suspensions punish indigent people more harshly and are irrational/counterproductive; Griffin/Bearden principles apply. | Benson: wealth-classification claims get rational-basis review; the suspension regime is rationally related to legitimate interests (deterrence, compliance, collection). | Majority: Griffin line not controlling here; rational-basis applies and the suspension scheme is rationally related to legitimate state interests; claim fails. |
| Extraordinary debt-collection (James v. Strange): does the scheme impose a harsher collection method on those who owe court debt vs. other debtors? | Plaintiffs: license suspension is a uniquely harsh state collection method against indigents and lacks parity protections required by Strange. | Benson: Strange concerned stripping ordinary exemptions for indigent criminal defendants; Michigan preserves ordinary exemptions and the State has unique authority over licenses; rational-basis applies. | Majority: Strange does not invalidate Michigan’s approach; suspension survives rational-basis review. |
| Jurisdictional defenses (standing, Rooker–Feldman, abstention) | Plaintiffs: facial and factual record support standing and federal review of Secretary action; district court proper to hear case. | Benson: factual disputes undermine standing; claims are effectively appeals of state-court judgments (Rooker–Feldman); federal court should abstain. | Court: Plaintiffs have standing; Rooker–Feldman inapplicable because the Secretary’s suspension (not state-court judgments) is the actionable source of injury; Pullman/Younger abstention not required. |
Key Cases Cited
- Bd. of Regents of State Colleges v. Roth, 408 U.S. 564 (1972) (property interests are created by state law/rules and define the scope of due process protections)
- Bell v. Burson, 402 U.S. 535 (1971) (driver’s license is a protected interest; scope of pre-deprivation process depends on whether relevant factors are part of the statutory scheme)
- Mathews v. Eldridge, 424 U.S. 319 (1976) (three-factor balancing test for what process is due)
- Griffin v. Illinois, 351 U.S. 12 (1956) (indigent defendants cannot be denied appellate review mechanism solely due to indigency)
- Bearden v. Georgia, 461 U.S. 660 (1983) (revocation of probation for nonpayment requires inquiry into ability/willingness to pay and consideration of alternatives)
- James v. Strange, 407 U.S. 128 (1972) (state may not subject indigent criminal defendants to harsher collection procedures that strip ordinary exemptions)
- Dixon v. Love, 431 U.S. 105 (1977) (upheld certain post-deprivation procedures for license suspensions where risk of erroneous deprivation was low)
- Mackey v. Montrym, 443 U.S. 1 (1979) (recognizes protectible property interest in driver’s license)