Ratches v. Guerrera
3:24-cv-01319
D. Conn.May 15, 2025Background
- Jake Ratches, an unsentenced inmate at Hartford Correctional Center, sued Connecticut DMV Commissioner Tony Guerrera and Governor Ned Lamont after his driver’s license was suspended following a 2018 DUI arrest.
- Ratches claims his license remains suspended and subject to an ignition interlock device requirement, even though his DUI charges were dismissed as a nolle prosequi in 2022.
- He sought a temporary restraining order and preliminary injunction to prevent continued suspension and to remove the ignition interlock requirement, alleging violations of the Fourteenth Amendment Due Process Clause, the Fifth Amendment Double Jeopardy Clause, and potentially the Eighth Amendment Excessive Fines Clause.
- The administrative suspension and ignition interlock requirement were imposed by the DMV, which acts independently of the criminal prosecution for DUI.
- The legal question was whether the ongoing license suspension and interlock requirement violate Ratches’s constitutional rights despite an acquittal or dismissal in criminal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Irreparable Harm | Cannot renew license due to interlock requirement while incarcerated, risking permanent loss of driving privilege | Harm is monetary/repairable; no urgent threat; can retake test if license expires | No irreparable harm; delay undermines urgency |
| Fourteenth Amendment Due Process | DMV process insufficient, especially after dismissal of DUI charge | Suspension/requirement followed statutory procedure with notice, hearing, and appeal | Statutory procedures adequate; no due process violation |
| Fifth Amendment Double Jeopardy | Ongoing administrative sanctions after case resolved = double punishment | License suspension is civil/remedial, not punitive; not covered by double jeopardy clause | Administrative suspension is civil; double jeopardy not implicated |
| Eighth Amendment Excessive Fines | Interlock device requirement after dismissed charge is excessive fine | Requirement is remedial, not punitive; statute aims to protect public | Requirement is not a punitive fine; no excessive fines violation |
Key Cases Cited
- Moore v. Consolidated Edison Co. of N.Y., 409 F.3d 506 (2d Cir. 2005) (standard for preliminary injunctive relief)
- Mazurek v. Armstrong, 520 U.S. 968 (1997) (preliminary injunction is drastic and requires clear showing)
- Hudson v. United States, 522 U.S. 93 (1997) (double jeopardy applies only to criminal, not civil, sanctions)
- United States v. Bajakajian, 524 U.S. 321 (1998) (test for excessive fines under the Eighth Amendment)
- Breed v. Jones, 421 U.S. 519 (1975) (double jeopardy attaches only to criminal proceedings)