Stinnie v. Holcomb, 396 F.Supp.3d 653

Plaintiffs (Stinnie et al.) challenge Va. Code § 46.2-395, which mandates automatic driver’s license suspension for failure to pay court fines and costs, on procedural due process and equal protection grounds; they seek class certification and injunctive relief.
Court previously granted a preliminary injunction, finding likely success on a procedural due process claim.
Virginia enacted Budget Amendment No. 33, which (temporarily, through July 1, 2020) prevents courts from suspending driving privileges solely for nonpayment of fines/costs, directs DMV to reinstate affected licenses and waive reinstatement fees, but does not repeal § 46.2-395.
The Commissioner moved to dismiss the case as moot (or prudentially moot) based on the Budget Amendment, or alternatively to stay the litigation pending the 2020 General Assembly session.
The Court held the case is not constitutionally or prudentially moot because § 46.2-395 remains law and reenactment/enforcement remains reasonably possible, but concluded that a stay is appropriate given legislative activity, judicial-economy principles, and limited prejudice to plaintiffs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Budget Amendment renders case constitutionally moot	Stinnie: Harm remains because statute still exists and enforcement could resume	Holcomb: Amendment halts enforcement; no reasonable expectation of reenactment; moot	Denied—case not constitutionally moot (future enforcement reasonably possible)
Whether case is prudentially moot	Stinnie: Harm is more than speculative; continuing ‘‘brooding presence’’ exists	Holcomb: Cessation of enforcement is real and speculative future harm does not justify relief	Denied—court will not apply prudential mootness; harm not merely hypothetical
Whether to stay proceedings pending legislative action	Stinnie: Stay would delay relief and could prejudice plaintiffs	Holcomb: Stay avoids waste of resources, prevents moot litigation if repeal occurs	Granted—stay appropriate due to judicial economy, constitutional avoidance, limited prejudice to plaintiffs
Scope/effect of Budget Amendment on class members	Stinnie: Amendment may not fully protect class or address future suspensions	Holcomb: DMV will mark § 46.2-395 suspensions as complied with and waive fees; other suspensions remain	Court accepts DMV interpretation for stay purposes; plaintiffs not at risk under § 46.2-395 until July 1, 2020; litigation stayed pending legislative outcome

Lewis v. Continental Bank Corp., 494 U.S. 472 (U.S. 1990) (Article III case-or-controversy requirement applies through all stages of litigation)
City of Erie v. Pap’s A.M., 529 U.S. 277 (U.S. 2000) (mootness occurs when issues are no longer live or parties lack legally cognizable interest)
Brooks v. Vassar, 462 F.3d 341 (4th Cir. 2006) (statutory amendment can moot a challenge if reenactment is not reasonably expected)
Mellen v. Bunting, 327 F.3d 355 (4th Cir. 2003) (case not moot where reasonable expectation of repeated harm exists)
Reyes v. City of Lynchburg, 300 F.3d 449 (4th Cir. 2002) (finding lack of reasonable expectation of reenactment can support mootness)
Preiser v. Newkirk, 422 U.S. 395 (U.S. 1975) (‘‘continuing and brooding’’ presence standard relevant to equitable relief)
Ashwander v. Tennessee Valley Authority, 297 U.S. 288 (U.S. 1936) (prudential principle of constitutional avoidance)
Catawba Riverkeeper Found. v. N.C. Dep’t of Transp., 843 F.3d 583 (4th Cir. 2016) (prudential mootness requires harm not merely hypothetical)
Doe v. Va. Dep’t of State Police, 713 F.3d 745 (4th Cir. 2013) (prudential limits on federal jurisdiction and judicial restraint)