City of St. Peters, Missouri v. Bonnie A. Roeder
466 S.W.3d 538
Mo.2015Background
- The City of St. Peters enacted ordinance 4536 authorizing automated red light enforcement and creating a moving-violation offense under City Traffic Code 315.030.
- Ordinance 4536 states that no points will be assessed for a conviction detected through the automated red light system.
- Bonnie Roeder received a June 15, 2012 notice of violation under ordinance 4536 and pending options (pay fine, affidavit of non-responsibility, or court appearance).
- Roeder was convicted by jury of violating ordinance 4536 and fined $110; she later moved to dismiss arguing conflicts with state law, improper notice, and equal protection concerns.
- The trial court dismissed Roeder’s charge after applying Unverferth v. Florissant; the Court of Appeals transferred the case to the Missouri Supreme Court for review.
- The Supreme Court held that ordinance 4536 conflicts with section 302.302.1 by prohibiting point assessment for a moving violation and that severance is allowed but enforceable prospectively only, leading to dismissal of Roeder’s charge on due-process grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does ordinance 4536 conflict with state law on points assessment? | Roeder: no points conflicts with 302.302.1. | City: 302.302 allows non-point classifications via director; charge code controls; severability applies. | Yes, conflict exists; no-points clause conflicts with mandatory two points. |
| Is severance of the invalid no-points provision proper, and can remaining provisions be enforced for Roeder? | Roeder: severance would violate her notice and due process. | City: severance permitted if legislature would have enacted ordinance without invalid provision. | Severance allowed but enforcement to Roeder must be prospective only due to due-process/fair-notice concerns. |
| Does the notice of violation or implied burden-shifting affect Roeder’s due process rights? | Roeder: notice creates an implied burden-shifting presumption that owner is operator. | City: notice aligns with owner liability and pursuit of trial evidence. | Not decisive to affirm; main ruling rests on conflict and severance grounds; due-process concerns acknowledged in dissenting view. |
Key Cases Cited
- Unverferth v. City of Florissant, 419 S.W.3d 76 (Mo. App. 2013) (red light camera presumption issues in moving violations)
- Brunner v. City of Arnold, 427 S.W.3d 201 (Mo. App. E.D. 2013) (rebuttable presumption issues in red light camera cases; may be criminal)
- Edwards v. City of Ellisville, 426 S.W.3d 644 (Mo. App. 2013) (moving violations; point system context)
- Page W., Inc. v. Cmty. Fire Prot. Dist. of St Louis Cnty., 636 S.W.2d 65 (Mo. banc 1982) (statutory interpretation to resolve conflicts with general law)
- Strode v. Dir. of Revenue, 724 S.W.2d 245 (Mo. banc 1987) (conflict between ordinance and state law; moving violation framework)
- McCollum v. Dir. of Revenue, 906 S.W.2d 368 (Mo. banc 1995) (severability and state-law preemption considerations)
- Rudd v. David, 444 S.W.2d 457 (Mo. 1969) (two-point regulatory framework; points not punitive)
- Barbieri v. Morris, 315 S.W.2d 711 (Mo. 1958) (retrospective penalties under point system context)
- Tupper v. City of St. Louis, 468 S.W.3d 360 (Mo. banc 2015) (rebuttable presumption analysis in red light camera ordinances)