81 F. Supp. 3d 211
E.D.N.Y2015Background
- Plaintiff Claire F. Leder sued ATS, ATS Consolidated, and the Nassau County Traffic and Parking Violations Agency alleging Nassau’s red‑light camera program issued invalid tickets from 2009 onward by operating yellow lights shorter than federal/state guidelines.
- Plaintiff received a Notice of Liability for a November 22, 2010 red‑light violation, paid the $65 fine, and did not contest it.
- Plaintiff asserted: (1) § 1983 due process claims (federal and state substantive due process), (2) NY Civil Rights Law § 11 claim, (3) unjust enrichment, and (4) requests for declaratory and injunctive relief to stop the RLC program or require compliance with standards.
- Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6). Plaintiff withdrew some claims and abandoned others in opposition.
- The court treated the Notice of Liability as incorporated by reference, found standing for monetary relief but not for injunctive relief, and dismissed the complaint in full.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing for monetary § 1983 relief | Payment of $65 is an injury-in-fact traceable to defendants’ conduct and redressable by damages | Plaintiff’s voluntary payment severs causation; lacks redressability for injunctive relief | Standing exists for monetary damages (injury, causation, redressability); no standing for injunctive relief (no likelihood of future injury) |
| Substantive due process (§ 1983 and NY Const.) | Shortened yellow intervals and resulting fines amount to arbitrary, conscience‑shocking government action violating substantive due process | Alleged conduct is not the type of arbitrary, outrageous state action protected by substantive due process; defendants acted with statutory authority | Dismissed: $65 fine is not a protected fundamental interest; allegations do not plead conscience‑shocking, ultra vires conduct |
| Unjust enrichment | Defendants were enriched at plaintiff’s expense by issuing extra camera tickets; equity requires return | Claim duplicates constitutional and other causes of action; plaintiff voluntarily paid and had review process available | Dismissed: duplicative of failed claims and equity does not require refund where plaintiff voluntarily paid without contesting |
| Declaratory and injunctive relief to compel compliance with standards | Court should declare RLC noncompliant and enjoin operation until compliant | No live claim because substantive and equitable claims fail; plaintiff lacks standing for injunction | Dismissed: injunctive/declaratory relief fails for lack of standing and because underlying claims are meritless |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard governs Rule 12(b)(6))
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing requirements: injury, causation, redressability)
- City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (injunctive relief requires likelihood of future injury)
- Collins v. City of Harker Heights, Tex., 503 U.S. 115 (1992) (courts reluctant to expand substantive due process; limited scope)
- Cine SK8 v. Town of Henrietta, 507 F.3d 778 (2d Cir. 2007) (ultra vires governmental acts can support substantive due process claim)
- Corsello v. Verizon New York, Inc., 18 N.Y.3d 777 (2012) (unjust enrichment is not a catchall and is duplicative where other claims govern)