Amick v. Director of Revenue
2014 Mo. LEXIS 109
| Mo. | 2014Background
- Amick, convicted of felony driving while intoxicated, had driving privileges suspended for at least 10 years starting November 2008.
- In August 2013 Amick petitioned for limited driving privileges under section 302.309.1 and the director moved to dismiss under 302.309.3(6)(b) for ineligibility due to the felony.
- The circuit court granted the dismissal, concluding Amick was statutorily ineligible for limited driving privileges.
- Amick appealed, arguing that section 302.309.3 violates equal protection by treating DWI court participants differently from non-participants.
- The court applied rational-basis review, finding no equal-protection violation because driving privileges are not a fundamental right and the classification is rationally related to public safety.
- The judgment denying limited driving privileges was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 302.309.3(6)(b) and (9) violate equal protection. | Amick argues the statute discriminates against felons vs. DWI court participants. | State argues rational basis supports different treatment to promote public safety. | No equal-protection violation; rational-basis upheld. |
Key Cases Cited
- Weinschenk v. State, 203 S.W.3d 201 (Mo. banc 2006) (establishes rational-basis framework)
- State v. Young, 362 S.W.3d 386 (Mo. banc 2012) (two-step equal-protection analysis and scrutiny levels)
- Williams v. Schaffner, 477 S.W.2d 55 (Mo. banc 1972) (driving license as a privilege; permissible regulation)
- Stewart v. Director of Revenue, 702 S.W.2d 472 (Mo. banc 1986) (driving license regulation authority recognized)
- Bert v. Director of Revenue, 935 S.W.2d 319 (Mo. banc 1996) (burden on challenger to negate multiple rational bases)
- City of St. Louis v. State, 382 S.W.3d 905 (Mo. banc 2012) (illustrates rational-basis review standards)