Cedar Rapids v. Marla Marie Leaf, 16-0435

Background

Marla Leaf received an automated traffic enforcement (ATE) notice alleging her vehicle was recorded traveling 68 mph in a 55 mph zone on I-380 on Feb. 5, 2015; the notice sought a $75 civil fine.
Leaf contested administratively, then requested a municipal-infraction prosecution; a magistrate found the City proved the violation by clear, satisfactory, and convincing evidence and imposed the $75 fine plus costs.
The district court reviewed the small-claims record de novo, affirmed the magistrate, and rejected multiple constitutional and statutory challenges to Cedar Rapids’ ATE ordinance and its implementation.
Leaf sought discretionary review to the Iowa Supreme Court; the case was transferred to the Court of Appeals, which affirms the district court judgment.
Key contested legal issues included sufficiency of proof from camera evidence, procedural and substantive due process, equal protection, preemption by IDOT rules, and alleged unlawful delegation of police power to a private contractor (GATSO).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of proof that vehicle exceeded speed limit	Leaf: City failed to prove speed by clear, satisfactory, and convincing evidence; camera unreliable	City: camera calibration/testing and officer review establish accurate measurement	Held: City met burden; camera testing and officer review supported finding of violation
Procedural due process / access to courts	Leaf: ordinance and City practice impermissibly forced administrative route and thwarted direct access to district court	City: administrative hearing is optional; ordinance provides access to court before or after admin hearing	Held: No violation; administrative process is optional and adequate notice/opportunity provided
Substantive due process (right to travel / dignity)	Leaf: ATE enforcement and alleged violations of IDOT orders offend fundamental rights and fairness	City: challenges addressed and rejected in prior authority; enforcement furthers safety	Held: Rejected; no substantive due process violation
Equal protection / under-inclusive enforcement	Leaf: selective operation (e.g., rear-plate capture, database gaps) bears no rational relation to safety	City: enforcement advances safety; differential impact not unconstitutional	Held: Rejected; court finds no equal protection violation
Preemption by IDOT rules / enforcement of IDOT order	Leaf: IDOT calibration/placement rules and an IDOT order preempt or invalidate citations from the camera location	City: ordinance does not conflict with IDOT rules; placement/dispute with IDOT is separate administrative matter; Leaf did not preserve preemption claim	Held: Rejected as preserved and ripe; ordinance not preempted and Leaf not entitled to remedy based on placement dispute
Unlawful delegation of police powers to private contractor (GATSO)	Leaf: City unconstitutionally delegated enforcement discretion to GATSO	City: GATSO maintains equipment and forwards potential violations, but CRPD makes final citation decisions	Held: Rejected; no unconstitutional delegation because police retained ultimate discretion

Key Cases Cited

De Stefano v. Apts. Downtown, Inc., 879 N.W.2d 155 (Iowa 2016) (standard of review for small-claims appeals tried at law)
Smith v. State, 845 N.W.2d 51 (Iowa 2014) (appellate review and deference to factual findings supported by substantial evidence)
City of Sioux City v. Jacobsma, 862 N.W.2d 335 (Iowa 2015) (constitutional claims reviewed de novo; home-rule preemption principles)
Hughes v. City of Cedar Rapids, 840 F.3d 987 (8th Cir. 2016) (upholding ATE ordinance against due process, preemption, and delegation challenges)
Brooks v. City of Des Moines, 844 F.3d 978 (8th Cir. 2016) (ATE ordinance not preempted by state law)
Bowers v. Polk County Bd. of Supervisors, 638 N.W.2d 682 (Iowa 2002) (procedural due process requires notice and adequate opportunity to be heard)