Stinnie v. Holcomb, 355 F. Supp. 3d 514

Plaintiffs are Virginia residents whose driver's licenses were suspended automatically under Va. Code § 46.2-395 for failure to pay state court fines and costs; suspensions occur after courts transmit default data to DMV without a separate court order or additional notice.
DMV/Commissioner records and effects suspensions automatically when court systems indicate nonpayment; DMV sends a post-suspension letter and requires a $145 reinstatement fee to lift suspensions.
Plaintiffs say they were never asked about their inability to pay and were not given any pre-suspension opportunity to be heard; loss of license affected employment, medical access, and family life.
Procedurally: plaintiffs seek a preliminary injunction to stop enforcement of § 46.2-395 without notice and an ability-to-pay determination, to remove current suspensions, and to bar reinstatement fees where no other restriction exists.
The Commissioner moved to dismiss for lack of jurisdiction (Rooker–Feldman), lack of Article III standing, and Eleventh Amendment immunity; the court rejected those jurisdictional arguments.
The district court found plaintiffs likely to succeed on their procedural due process claim and granted a preliminary injunction based on lack of any meaningful pre-deprivation hearing and deficient notice practices.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker–Feldman bars the suit	Plaintiffs challenge the statute/administrative suspension, not state-court judgments	Commissioner says relief would effectively overturn state-court outcomes	Rooker–Feldman does not apply; plaintiffs present an independent challenge to the statute and administrative action
Article III standing (traceability/redressability)	Commissioner's implementation of § 46.2-395 causes suspensions and collects reinstatement fees; injunctive relief would restore driving	Commissioner contends injuries are not traceable or redressable to his actions alone	Standing satisfied: suspensions and fee collection are traceable to and redressable by injunctive relief against the Commissioner
Eleventh Amendment immunity / Ex Parte Young	Plaintiffs sue Commissioner in official capacity to enjoin enforcement	Commissioner claims sovereign immunity bars suit	Ex Parte Young applies; Commissioner has statutory duties and enforcement connection, so suit may proceed
Procedural due process — notice & hearing (Mathews factors)	§ 46.2-395 allows automatic suspension without pre-deprivation hearing or meaningful notice and lacks ability-to-pay inquiry	Commissioner points to sentencing/appeal/payment-plan procedures and Rule 1:24 / § 19.2‑354.1 as safeguards	Court: plaintiffs likely to succeed on procedural due process claim — statute provides inadequate opportunity to be heard and notice is deficient; injunction granted

District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (limits federal review of state-court judgments)
Thana v. Bd. of License Comm'rs for Charles Cty., Md., 827 F.3d 314 (4th Cir. 2016) (discusses independent federal claims vs. Rooker–Feldman)
Skinner v. Switzer, 562 U.S. 521 (U.S. 2011) (statutory challenges to state procedures may be heard in federal court)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (federal jurisdiction where plaintiff presents independent claim)
Doe v. Va. Dep't of State Police, 713 F.3d 745 (4th Cir. 2013) (standing where defendant implemented challenged statutory scheme)
Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor test for what process is due)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (notice must be reasonably calculated to inform interested parties)
Snider Int'l Corp. v. Town of Forest Heights, 739 F.3d 140 (4th Cir. 2014) (notice by mail and availability of a hearing analyzed)
Plumer v. Maryland, 915 F.2d 927 (4th Cir. 1990) (driver's license is property interest protected by due process)
Bell v. Burson, 402 U.S. 535 (U.S. 1971) (state must afford notice and opportunity to be heard before terminating license)
Ex Parte Young, 209 U.S. 123 (U.S. 1908) (permits official-capacity suits to enjoin enforcement of unconstitutional state laws)