State of Indiana and Indiana Bureau of Motor Vehicles v. Thomas H. Miracle (mem. dec.)
2017 Ind. App. LEXIS 203
| Ind. Ct. App. | 2017Background
- Thomas Miracle faced infractions and driving-related convictions from 2010–2011, including failures to provide proof of insurance and seat belt violations; several administrative suspensions were imposed by the Indiana BMV for failure to provide evidence of financial responsibility.
- In March 2016 the trial court, during infraction proceedings, ordered the BMV to expunge multiple convictions and suspensions from Miracle’s driving record, including two BMV-imposed suspensions spanning Jan. 30, 2011–Apr. 30, 2011 and Jan. 30, 2011–Jan. 30, 2012.
- The BMV intervened and moved to correct error, arguing the trial court lacked authority to expunge BMV-imposed administrative suspensions tied to failure to provide evidence of financial responsibility (citing I.C. § 9-25-9-1(c)).
- The trial court denied the BMV’s motion to correct error; the BMV appealed. Miracle did not file an appellee brief.
- The Court of Appeals reviewed for abuse of discretion and analyzed deference to agency statutory interpretations where appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had authority to order expungement of BMV administrative suspensions imposed for failure to provide evidence of financial responsibility | BMV: trial court lacked authority; expungement cannot alter BMV penalties under statute | Miracle: expungement appropriate as part of resolving infractions and payment issues | Court reversed: trial court abused discretion; it could not expunge the two specified BMV suspensions |
Key Cases Cited
- Wharton v. State, 42 N.E.3d 539 (Ind. Ct. App. 2015) (appellee’s failure to brief permits review for prima facie error)
- Indiana Bureau of Motor Vehicles v. Hargrave, 51 N.E.3d 255 (Ind. Ct. App. 2016) (deference to reasonable agency statutory interpretation)
- Indiana Bureau of Motor Vehicles v. Watson, 70 N.E.3d 380 (Ind. Ct. App. 2017) (abuse of discretion defined with respect to misinterpretation of law)
- Ind. Wholesale Wine & Liquor Co. v. State ex rel. Ind. Alcoholic Beverage Comm’n, 695 N.E.2d 99 (Ind. 1998) (recognizing deference to administrative agency interpretations)