Tuesday, March 2, 2010

City of Springfield v. Adolph Belt, Jr.[1]

Opinion handed down March 2, 2010.
Link to Mo. Sup. Ct. Opinion

The Supreme Court of Missouri held that the City of Springfield's adjudication process for tickets issued from automated red light cameras was void.[2]

I. Facts and Holding

From 2007 to 2010, the City of Springfield, Missouri, operated automated red light cameras at intersections within the city limits.[3] The camera system was designed to promote safety and enable prosecutions for red light-runners by photographing those cars that entered an intersection after the stoplight turned red.[4] Violators were fined $100 for this infraction.[5]

When one of these cameras photographed Adolph Belt, Jr.'s car at one of these intersections, the City charged him with a violation of its red light ordinance.[6] A 35-year veteran of the Missouri State Highway Patrol and the Kansas City Police Department, Belt conducted his own investigation into the intersection and camera system, finding several deficiencies.[7]

Belt was given 30 days to contest the charge or pay a $100 fine.[8] Contesting the charge required that he "request a court date" and "appear in court."[9] When Belt requested his court date, he received a notice that he would have to appear at the "Springfield Municipal Court."[10] The notice also mentioned the other principals at the hearing: a "Hearing Officer" and the City's "Office of the Municipal Prosecutor."[11]

At his hearing, Belt testified about his experience with traffic accidents and that he had personally timed the shortened yellow-light cycle.[12] The Hearing Officer, who was also a Springfield Municipal Judge, found that no evidence supported Belt's contention that the yellow light was displayed for less than 4.5 seconds and fined him $100 for violating the City's red light ordinance.[13]

Belt then applied for a trial de novo with the Greene County circuit court.[14] The court granted the City's motion to dismiss on the grounds that the court lacked jurisdiction to hear a case decided by an administrative hearing.[15] Belt appealed to the Court of Appeals, Southern District, which rejected his claim,[16] and the Supreme Court of Missouri accepted transfer.[17]

The Supreme Court of Missouri reversed, holding that the administrative hearing process used by the City was "void."[18] The City argued that its adjudication process was valid because it was an administrative hearing, from which appeals are not allowed.[19] However, Belt argued – and the Court agreed – that the City was required to adjudicate municipal ordinance violations before a municipal judge or associate circuit judge, not in an administrative hearing.[20] Belt's fine was vacated as a result.[21]

II. Legal Background

Missouri law allows adjudication of municipal ordinance violations by a court or administrative hearing. Which process may be used depends on the governance of the municipality, the type of violation, and the decisions of the municipal governments.[22]

Municipal governments in Missouri generally must try ordinance violations in a division of the circuit court in which the city is located.[23] This may occur in either the circuit court's associate division or a city's municipal court (which is itself an associate division of the circuit court).[24] However, any city that is either not in a county (St. Louis) or lies in more than one county and has at least 400,000 inhabitants (Kansas City) may establish an administrative hearing system.[25] If the municipality decides to create an administrative hearing system, this system may be used for "adjudicating parking and other civil, nonmoving municipal code violations."[26]

The City of Springfield's administrative hearing system for red light tickets was invalid because the city met none of these requirements: Springfield is located wholly within Greene County and has less than 400,000 residents, making it ineligible to create a hearing system.[27] Even if Springfield were allowed an administrative hearing system, adjudicating red light violations would not have been appropriate because the act of running a red light is inherently a "moving" violation,[28] despite the City's apparent position to the contrary.[29] Further, the use of municipal judges as hearing officers might violate the statutory ban on municipal judges holding other public offices for the municipality in which they hold court.[30]

III. Comment

An administrative hearing system creates two advantages for a city such as Springfield. First, evidentiary and procedural rules are relaxed and may be set by the hearing authority.[31] Second, administrative hearings are not subject to judicial review.[32] Between June of 2007 when the cameras went up and the release of this opinion on March 2, 2010, Springfield issued 9,784 tickets and collected approximately $803,000 in fine revenue.[33] Thus a system that allows for low-effort, final resolutions should be highly desirable for a municipality trying to process thousands of tickets produced by its red light cameras. While these advantages (and the cost advantages that surely come with) may be highly desirable to the city, they violate statutory protections given to drivers on its roads. Judge Wolff summed up that unavoidable conflict as he began the court's opinion: "This is a $100 case. But sometimes, it's not the money – it's the principle."[34]

- Cole David Bradbury

[1] No. SC 90324 (Mo. March 2, 2010). The West reporter citation is City of Springfield v. Belt, 307 S.W.3d 649 (Mo. banc 2010).
[2] Id., slip op. at 2.
[3] City of Springfield, Red Light Camera Questions and Answers (April 29, 2007), available at http://www.springfieldmo.gov/cityconnect/getPost.jsp?entryid=7.
[4] Id.
[5] Id.
[6] Belt, No. SC 90324, slip op. at 2. A related ordinance, Springfield City Code 106-155(5), defined the violation as a "civil, non-point penalty." Id., slip op. at 2 n.2.
[7] Id., slip op. at 3-4. Specifically, Belt found that the City had reduced the length of yellow lights at intersections around the city from the recommended 4.5 seconds to 3.5 to 3.8 seconds. Id., slip op. at 4 n.4.
[8] Id., slip op. at 2-3.
[9] Id.
[10] Id., slip op. at 3.
[11] Id.
[12] Id., slip op. at 3-4.
[13] Id.., slip op. at 4.
[14] Id., slip op. at 5.
[15] Id.
[16] City of Springfield v. Belt, 2009 WL 1953437 (Mo. App. S.D. 2009), withdrawn.
[17] Belt, No. SC 90324, slip op. at 5.
[18] Id., slip op. at 8.
[19] Id., slip op. at 5.
[20] Id., slip op. at 6.
[21] Id., slip op. at 8.
[22] See Mo. Rev. Stat. § 479.010 (Supp. 2009). All statutory references are to the 2009 Supplement.
[23] Id. at § 479.010.
[24] Id. at § 479.040.
[25] Id. at § 479.011 ("Any city not within a county or any home rule city with more than four hundred thousand inhabitants and located in more than one county.").
[26] Id.
[27] Belt, No. SC 90324, slip op. at 6.
[28] Id., slip op. at 6-7.
[29] City of Springfield, Red Light Camera Questions and Answers (April 29, 2007), available at http://www.springfieldmo.gov/cityconnect/getPost.jsp?entryid=7 ("Is the [red light] citation a traffic ticket? A: No, it is not considered a moving violation. It is a civil citation holding the registered owner or lessee responsible for the violation (similar to a parking ticket). No points [on the defendant's driver's license] can be assessed for this citation.")
[30] Belt, No. SC 90324, slip op. at 7 n.9 (citing Mo. Rev. Stat. § 479.020.6).
[31] Mo. Rev. Stat. § 479.011.2 ("The administrative tribunal shall adopt policies and procedures for administrative hearings . . ."); § 479.011.3 ("The formal rules of evidence shall not apply in any administrative review or hearing authorized in this section. Evidence, including hearsay, may be admitted only if it is the type of evidence commonly relied upon by reasonably prudent persons in the conduct of their affairs.").
[32] Compare Mo. Rev. Stat. § 479.011.5 ("Any final decision or disposition of a code violation by an administrative tribunal shall constitute a final determination for purposes of judicial review.") with § 479.200.2 ("In any case tried before a municipal judge . . . or before an associate circuit judge, except where there has been a plea of guilty or the case has been tried with a jury, the defendant shall have a right of trial de novo before a circuit judge or upon assignment before an associate circuit judge.").
[33] Amos Bridges, "Court puts brakes on Springfield's red light cameras," Springfield News-Leader, March 3, 2010, at A1, available at http://www.news-leader.com/article/20100303/NEWS01/3030498/Missouri-Supreme-Court-puts-brakes-on-Springfield-s-red-light-cameras.
[34] Belt, No. SC 90324, slip op. at 1.