Tate v. District of Columbia
393 U.S. App. D.C. 270
| D.C. Cir. | 2010Background
- Tate challenged the 2002 impoundment and sale of her car by the District after unpaid tickets, asserting four §1983 claims and five DC common-law torts; DPW booted the vehicle on March 12, 2002 due to multiple outstanding tickets and towed it to an impound lot; a May 29, 2002 hearing addressed the fees and sale status but the vehicle was later sold on June 4, 2002 for $4,000 after notice issues; notices were sent to the wrong address, contributing to lapse in reclamation time; Tate filed suit November 12, 2002 in district court and the district court granted summary judgment on all nine counts; the DC Circuit affirmed summary judgment on the §1983 claims and remanded the common-law claims for possible dismissal or merits consideration; Tate is proceeding pro se in the district court for the DC common-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process adequacy from notice/hearing | Tate claims premature sale and improper notice violated due process | District provided meaningful notice and hearings | Due process satisfied; no deprivation of process shown |
| Takings under the Fifth Amendment | Sale constituted unconstitutional taking requiring compensation | Process-based forfeiture aligns with governmental authority; no taking | Not a taking; process-based, with no compensation due |
| Equal protection under the Fifth Amendment | District treated Tate differently from others; selective enforcement | Rational basis review applies; line drawn was rational and within legislative prerogative | No equal protection violation; rational basis upheld |
| Unreasonable seizure under the Fourth Amendment | Booting/towing and sale constituted unreasonable seizure | Graduated forfeiture regime permits warrantless seizure; reasonable under doctrine | Not an unreasonable seizure; consistent with statutory regime and precedent |
| Disposition of common-law claims | Common-law claims were merits-arguable despite failure to address them separately | District court treated them as conceded under LCvR 7(b) | Remanded for district court to address merits or dismiss without prejudice |
Key Cases Cited
- Florida v. White, 526 U.S. 559 (1999) (upheld warrantless seizure of contraband automobile with probable cause)
- Bennis v. Michigan, 516 U.S. 442 (1996) (forfeiture not a taking when government lawfully acquires property)
- Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (class-of-one equal protection principle; arbitrary treatment requires justification)
- Luck v. D.C. Parole Bd., 996 F.2d 372 (1993) (upholds rational basis for line-drawing in regulatory classifications)
- U.S. R.R. Ret. Bd. v. Fritz, 449 U.S. 166 (1980) (line-drawing in distributing benefits is legislative, not judicial)
- Mathews v. Eldridge, 424 U.S. 319 (1976) (due process requires meaningful opportunity to be heard)
- Saukstelis v. City of Chicago, 932 F.2d 1171 (1991) (booting as deterrent/remedial, not caretaking)