641 F. App'x 194
3d Cir.2016Background
- Pro se plaintiff Rodney L. Burr sued to invalidate Delaware’s seatbelt law, asserting a constitutional right not to wear a seatbelt.
- Burr relied on the Fourth, Fifth, Ninth, and Fourteenth Amendments and argued Lawrence v. Texas’s overruling of Bowers v. Hardwick means strict scrutiny should apply to seatbelt laws.
- The Attorney General moved to dismiss for failure to state a claim, arguing rational basis review applies and the law advances legitimate interests.
- The District Court granted dismissal and denied Burr’s motion for reconsideration; Burr appealed.
- The Third Circuit reviewed de novo whether the complaint plausibly alleged entitlement to relief and considered whether strict scrutiny was required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether strict scrutiny applies to Delaware’s seatbelt law | Lawrence’s overruling of Bowers returns constitutional doctrine to a broad view of liberty, so Burr argues the right not to wear a seatbelt is a fundamental liberty requiring strict scrutiny | Seatbelt laws are safety regulations implicating no recognized fundamental right; rational basis applies and the law serves legitimate safety interests | Rational basis applies; strict scrutiny not warranted |
| Whether complaint states a claim under rational-basis review | N/A — Burr concedes failure if rational basis applies | The law is rationally related to legitimate government interests (public safety, protecting occupants and others) | Complaint fails to state a claim under rational-basis review; dismissal affirmed |
Key Cases Cited
- Bowers v. Hardwick, 478 U.S. 186 (U.S. 1986) (addressed constitutional privacy claims pre-Lawrence)
- Lawrence v. Texas, 539 U.S. 558 (U.S. 2003) (overruled Bowers and clarified substantive-due-process analysis)
- Obergefell v. Hodges, 576 U.S. _, 135 S. Ct. 2584 (U.S. 2015) (describes how courts identify fundamental liberties and limits the scope of protected personal choices)
- Picou v. Gillum, 874 F.2d 1519 (11th Cir. 1989) (upheld helmet/ safety law against privacy/due process challenge)
- Pac. Legal Found. v. Dep’t of Transp., 593 F.2d 1338 (D.C. Cir. 1979) (rejected privacy challenge to passive-restraint/ safety regulation)
- Simon v. Sargent, 409 U.S. 1020 (U.S. 1972) (summary affirmance upholding lower-court rejection of a claim that motorcycle-helmet law violated due process)