Sarah Brooks v. City of Des Moines
2016 U.S. App. LEXIS 21454
| 8th Cir. | 2016Background
- In 2011 Des Moines enacted an ordinance authorizing an Automatic Traffic Enforcement (ATE) system and contracted with Gatso to operate it; cameras generate Notices of Violation to vehicle owners for speeding/red-light events.
- Six drivers sued the City and Gatso alleging violations of federal due process, equal protection, privileges and immunities, the fundamental right to travel, and various Iowa statutory and common-law claims (including unjust enrichment and violations of IDOT standards).
- The case was removed to federal court; the district court dismissed the drivers’ claims for failure to state a claim and the drivers appealed.
- The Eighth Circuit first addressed Article III standing and held each driver had standing based on receipt of a Notice of Violation and potential monetary penalties.
- The court analyzed preemption and consistency with Iowa law (home rule, Iowa Code §§ 602.6101 and 364.22) and concluded the City’s scheme was not irreconcilable with those provisions because administrative proceedings are optional and appealable de novo.
- The court relied on reasoning from Hughes v. City of Cedar Rapids for several federal and state-law rulings, affirmed most dismissals, but remanded claims tied to alleged IDOT-rule violations for dismissal without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to sue in federal court | Receipt of Notices of Violation creates concrete injury and risk of penalties | No standing asserted or argued insufficient | Plaintiffs have Article III standing (Notice + potential monetary consequences) |
| Ordinance inconsistent with Iowa § 602.6101 (district court jurisdiction) | Administrative/municipal scheme displaces district court jurisdiction | Home-rule and § 364.22 permit municipal infractions and concurrent jurisdiction | Ordinance not irreconcilable; concurrent jurisdiction exists; claim fails |
| Violation of Iowa § 364.22 (delegation and hearing forum) | Ordinance improperly delegates enforcement to Gatso and avoids required district-court trial procedure | Administrative hearing is optional and appealable de novo; delegation issue resolved by Hughes | Delegation and forum challenges dismissed per Hughes; optional admin hearing is compatible with § 364.22 |
| Federal constitutional claims (due process, equal protection, privileges/immunities) | ATE process and enforcement violate federal rights | Process provides adequate procedures; Hughes controls | Federal claims dismissed per Hughes; no merit shown |
Key Cases Cited
- Hunter v. Underwood, 362 F.3d 468 (8th Cir. 2004) (federal courts must satisfy themselves of subject-matter jurisdiction)
- Young America Corp. v. Affiliated Comput. Servs., Inc., 424 F.3d 840 (8th Cir. 2005) (standing requirement; lack of standing deprives court of jurisdiction)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (Article III standing elements)
- Ariz. Right to Life Political Action Comm. v. Bayless, 320 F.3d 1002 (9th Cir. 2003) (threat of civil penalties supports standing)
- Horne v. U.S. Dep't of Agric., 750 F.3d 1128 (9th Cir. 2014) (monetary penalties are concrete injuries for standing)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167 (U.S. 2000) (redressability and traceability principles in standing analysis)
- Goodell v. Humboldt Cty., 575 N.W.2d 486 (Iowa 1998) (local ordinance inconsistent with state law only if irreconcilable)
- State v. Stueve, 150 N.W.2d 597 (Iowa 1967) (concurrent jurisdiction explained)
- City of Sioux City v. Jacobsma, 862 N.W.2d 335 (Iowa 2015) (Iowa Supreme Court rejected similar challenges to municipal procedures)