City of Sioux City v. Michael Jon Jacobsma, 862 N.W.2d 335

Background

Sioux City enacted an automated traffic enforcement (ATE) ordinance making the registered vehicle owner (or a “nominated party”) civilly liable for photographed speeding violations; the ordinance allows an administrative review by the chief or designee and appeal to municipal court.
On Aug. 6, 2012 ATE equipment photographed a vehicle registered to Michael Jacobsma traveling 67 mph in a 55 mph zone; Sioux City issued a notice of violation to Jacobsma.
Jacobsma disputed the citation, lost the administrative review, was issued a municipal infraction citation, and stipulated at the magistrate hearing that he was the registered owner and the vehicle was speeding; he offered no evidence that someone else was driving.
Jacobsma moved to dismiss raising three constitutional claims: (1) substantive due process (invalid presumption/vicarious liability), (2) violation of Iowa’s inalienable rights clause (art. I, §1), and (3) implied preemption/home-rule conflict with Iowa traffic statutes (ch. 321).
The magistrate found Jacobsma liable; the district court affirmed; the Iowa Supreme Court granted discretionary review and affirmed the district court.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substantive due process (federal & Iowa)	Jacobsma: ordinance creates an arbitrary presumption that owner is the driver and allows liability unless owner shows a stolen-vehicle report, denying fair opportunity to rebut.	City: civil penalty scheme imposes vicarious liability via a rebuttable presumption reasonably related to public‑safety objectives; administrative and appeal procedures satisfy procedural due process.	Court: Applied rational‑basis review (no fundamental right). Because Jacobsma stipulated ownership and speeding and offered no evidence he was not driving, the owner‑based prima facie case is rational and passes due process review.
Inalienable rights clause (Iowa Const. art. I, §1)	Jacobsma: presumption permits liability without proof of causal connection or special relationship, unreasonably infringing liberty/property rights protected by §1.	City: §1 rights are subject to reasonable police‑power regulations; ATE ordinance is a reasonable public‑safety regulation.	Court: §1 claim fails. Even under a somewhat stricter rational‑basis approach, the owner/photo prima facie scheme is a reasonable regulation of traffic safety and not arbitrary or unreasonable.
Preemption / municipal home rule	Jacobsma: ATE civil‑liability scheme conflicts with state traffic statutes (Iowa Code ch. 321), which govern moving violations and owner liability, so ordinance is impliedly preempted.	City: No irreconcilable conflict; Seymour allows municipalities to adopt traffic regulations and civil penalties where not inconsistent with chapter 321.	Court: Seymour controls; ordinance is not irreconcilable with state law and is not preempted.

Key Cases Cited

City of Davenport v. Seymour, 755 N.W.2d 533 (Iowa 2008) (upholding a municipal ATE ordinance against challenges and recognizing municipalities may adopt additional traffic regulation not in conflict with chapter 321)
Hensler v. City of Davenport, 790 N.W.2d 569 (Iowa 2010) (invalidating a municipal rebuttable presumption imposing parental negligence where the inference was too attenuated and irrational)
Iowa City v. Nolan, 239 N.W.2d 102 (Iowa 1976) (upholding prima facie liability of vehicle owner for parking violations and explaining burden is shifted to go forward with evidence)
Agomo v. Fenty, 916 A.2d 181 (D.C. 2007) (upholding an ATE ordinance imposing vicarious liability on registered owners with limited defenses and finding a rational connection between ownership and control)
Idris v. City of Chicago, 552 F.3d 564 (7th Cir. 2009) (upholding municipal photographic enforcement and owner liability under rational‑basis review for civil fines)
Gacke v. Pork Xtra, L.L.C., 684 N.W.2d 168 (Iowa 2004) (interpreting the inalienable‑rights clause in the context of property regulation)
State v. Seering, 701 N.W.2d 655 (Iowa 2005) (discussing standards for presumptions and rational fit under due process)