Gary Hughes v. City of Cedar Rapids
2016 U.S. App. LEXIS 19677
| 8th Cir. | 2016Background
- Cedar Rapids enacted an ordinance authorizing an Automated Traffic Enforcement (ATE) system and contracted with Gatso to operate cameras that issue Notices of Violation to vehicle owners.
- A group of drivers sued the City and Gatso alleging violations of procedural and substantive due process, the fundamental right to travel, Iowa Code § 602.6101 (improper delegation), and unjust enrichment; defendants removed the case to federal court.
- The district court dismissed some plaintiffs for lack of Article III standing and dismissed the remaining claims for failure to state a claim; plaintiffs appealed and sought remand for those lacking standing.
- Key factual posture: some plaintiffs never received notices; one plaintiff (Lee) had been found guilty under the ordinance; one plaintiff’s wife (Mazgaj’s wife) received a Notice while he was the driver.
- Administrative context: Iowa DOT issued a report finding certain Cedar Rapids cameras out of compliance and ordered removal of some cameras; the City’s appeal remains pending in state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing for plaintiffs who fear future enforcement (Hughes) | Fear of imminent ATE citations gives standing | No concrete injury; no costs incurred to mitigate; threat not sufficiently imminent | No standing; claim remanded to state court if removed originally |
| Third-party standing (Mazgaj, on behalf of wife) | Mazgaj can assert rights of his wife who received notice | No close-relationship/hindrance shown; claim is a generalized grievance | No third-party standing; remand required |
| Ripeness for plaintiff already convicted under ordinance (Lee) | Claims ready for adjudication because conviction occurred | Defendants argued not ripe | Ripeness satisfied; federal adjudication allowed |
| Procedural due process for plaintiffs who did not use contest procedure | Procedure itself is inadequate (sham) so injury exists even without using it | Failure to avail process defeats standing/claim | Plaintiffs have Article III standing; substantive challenge fails on merits (no due process violation) |
| Substantive due process/right to travel | ATE is a "speed trap" burdening interstate/intrastate travel | Ordinance is traffic regulation; does not impair right to interstate travel; not conscience-shocking | No substantive due process violation; no fundamental-right burden |
| Privileges & Immunities / Equal Protection (travel discrimination) | ATE disproportionately cites out-of-state drivers or discriminates | No allegation of intentional discrimination based on state residency; rational basis applies | No violation: plaintiffs did not plead discriminatory enforcement; ordinance survives rational-basis review |
| State-law claims based on IDOT standards | Violations of IDOT standards render ordinance invalid under state law | Federal courts should not convert state regulatory findings into federal constitutional invalidation; IDOT decision pending | State-law claims based on IDOT rules are unripe; dismiss without prejudice pending administrative resolution |
| Unjust enrichment / improper delegation (Iowa law, § 602.6101) | City unlawfully delegated police/judicial power to private contractor (Gatso); Gatso unjustly enriched | Municipal delegation permitted for ministerial functions; Iowa precedent allows private contractors for ATE | Claims fail now; no improper delegation shown; unjust-enrichment claim dismissed |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires injury, causation, redressability)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (federal courts may not exercise supplemental jurisdiction over claims lacking Article III standing)
- Mathews v. Eldridge, 424 U.S. 319 (three-factor balancing test for process due)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (redressability and standing principles)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; courts need not accept conclusory allegations)
- Kowalski v. Tesmer, 543 U.S. 125 (third-party standing requirements)
- Booker v. City of Saint Paul, 762 F.3d 730 (8th Cir. 2014) (application of Mathews balancing in traffic-enforcement context)
- Clapper v. Amnesty Int’l USA, 568 U.S. 398 (standing from substantial risk and mitigation costs)