Snider International Corporation v. Town of Forest Heights, MD, 739 F.3d 140

Maryland statute (§ 21-809) authorizes automated “speed monitoring systems” that mail civil citations (≤ $40) to registered vehicle owners for speeding ≥12 mph over the limit; recipients may pay or elect a District Court trial.
The statute requires citations include owner info, time/date/location, image, penalty, and “a signed statement by a duly authorized law enforcement officer.” Agencies must keep operator training, daily self-test logs, and independent calibration certificates on file.
Between 2010–2012 two Maryland towns issued 55 automated citations to the appellants by first-class mail; some were paid, some defaulted, some litigated in state court. No record indicated any citation was not received.
Appellants sued under 42 U.S.C. § 1983 claiming procedural and substantive due process violations: (1) first-class mail notice is constitutionally insufficient (they urged certified mail); (2) electronically signed citations cannot serve as sworn testimony at trial; and (3) statutory noncompliance with § 21-809(b).
The district court granted summary judgment for the towns as to the class of recipients who paid; appellants appealed only the merits for the “paid” classes. The Fourth Circuit reviewed de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of notice by first-class mail	First-class mail is unreliable for in personam claims; certified or signed-delivery mail required	First-class mail to MVA-registered addresses is reasonably calculated to give actual notice	First-class mail satisfied due process where sent to registration addresses and no indication of nondelivery
Admissibility of electronically-signed citations as sworn testimony	Electronic signatures do not state personal knowledge vs. belief and thus are not proper sworn testimony	Citations + ability to demand operator testimony and state-court trial cure any evidentiary concerns	No procedural due process violation; state-court procedures and trial availability adequate to protect rights
§ 21-809(b) noncompliance (state-law claim)	Statutory recordkeeping/admission requirements not met, denying required process	Even if state law violated, that does not establish a federal constitutional violation under § 1983	Fourth Circuit refused to convert alleged state-law violations into § 1983 federal due process claims
Substantive due process challenge to the program	Automated citations and procedures are arbitrary and egregious	Program furthers traffic safety; penalties are small and subject to judicial review	No substantive due process violation; conduct not the sort of egregious official action required

Mathews v. Eldridge, 424 U.S. 319 (1976) (framework for balancing private interest, risk of erroneous deprivation, and government interest in procedural due process)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (notice must be reasonably calculated to apprise interested parties of proceedings)
Dusenbery v. United States, 534 U.S. 161 (2002) (actual notice not required; adequacy judged by reasonable calculation to inform)
Jones v. Flowers, 547 U.S. 220 (2006) (government must take additional reasonable steps if it learns initial notice failed)
Mantavlos v. Anderson, 249 F.3d 301 (4th Cir. 2001) (§ 1983 requires deprivation of a federal right)
Clark v. Link, 855 F.2d 156 (4th Cir. 1988) (violations of state law alone do not give rise to § 1983 liability absent federal constitutional breach)
Plumer v. State of Md., 915 F.2d 927 (4th Cir. 1990) (applying Mathews to MVA license procedures; state procedures met due process)
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (substantive due process requires conduct so egregious it shocks the conscience)