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Case Name Stinnie v. Holcomb PB-VA-0007
Docket / Court 3:16-cv-00044-NKM ( W.D. Va. )
State/Territory Virginia
Case Type(s) Public Benefits / Government Services
Special Collection DOJ Civil Rights Division Statements of Interest
Attorney Organization Legal Services/Legal Aid
Case Summary
On July 6, 2016, indigent Virginia residents who had suffered indefinite suspension of their driver's licenses for failure to pay court costs and fines that they could not afford, brought this class action lawsuit in the U.S. District Court for the Western District of Virginia. The plaintiffs sued ... read more >
On July 6, 2016, indigent Virginia residents who had suffered indefinite suspension of their driver's licenses for failure to pay court costs and fines that they could not afford, brought this class action lawsuit in the U.S. District Court for the Western District of Virginia. The plaintiffs sued the Commissioner of the Virginia Department of Motor Vehicles under 42 U.S.C. § 1983. Represented by private attorneys, the plaintiffs sought declaratory and injunctive relief, and class certification. They claimed that the Commonwealth's scheme of suspending licenses to coerce payment of money owed to the courts unfairly punishes poor people for being poor, and that suspending their licenses was a violation of the due process and equal protection clauses of the U.S. Constitution.

On November 4, 2016, Magistrate Judge Joel C. Hoppe granted the NAACP's motion for leave to file an amicus brief. On November 20, 2016, the U.S. Department of Justice filed a Statement of Interest urging the Court to conclude that the plaintiffs had set fourth a plausible claim for relief that the alleged driver's license suspension practices used by the defendant violated the Fourteenth Amendment. The DOJ argued that suspension of a person's driver's license in response to the failure to pay court debt without providing a person with adequate notice and meaningful opportunity to be heard prior to the suspension constitutes a deprivation of a protected interest without due process in violation of the Fourteenth Amendment. Moreover, the DOJ argued that suspending the driver's licenses of those who fail to pay fines without inquiring into whether the failure to pay was willful or instead the result of an inability to pay may result in penalizing indigent individuals solely because of their poverty, in violation of the due process and equal protection clauses of the Fourteenth Amendment.

On March 13, 2017, the court dismissed the case without prejudice. Judge Moon held that the court lacked jurisdiction to hear the case. The court found that "Congress and the Constitution have not granted federal district courts the authority to hear appeals from state courts." The court also found that a federal court could only hear a case if it could grant some sort of remedy to the plaintiffs. Finding that in this case, state courts rather than the Commissioner had suspended the licenses, a court order against the Commissioner would not provide such a remedy and so the court held it had no standing. Finally, the court found that it is barred from hearing the case by the Eleventh Amendment bar on federal lawsuits filed by citizens against a state. 2017 WL 963234.

The plaintiffs appealed, and the case is currently ongoing in the Fourth Circuit.

Saeeda Joseph-Charles - 11/20/2016
Virginia Weeks - 03/15/2018


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
Defendant-type
Jurisdiction-wide
General
Drivers Licenses
Poverty/homelessness
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Richard D. Holcomb
Plaintiff Description Individuals who allege that the DMV indefinitely suspended their driver’s licenses as a result of inability to pay fines and court costs.
Indexed Lawyer Organizations Legal Services/Legal Aid
Class action status sought Yes
Class action status granted Pending
Filed Pro Se No
Prevailing Party None Yet / None
Public Int. Lawyer Yes
Nature of Relief None yet
Source of Relief None yet
Filing Year 2016
Case Ongoing Yes
Docket(s)
3:16-cv-00044-NKM (W.D. Va.)
PB-VA-0007-9000.pdf | Detail
Date: 07/21/2017
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
PB-VA-0007-0001.pdf | Detail
Date: 07/06/2016
Source: PACER [Public Access to Court Electronic Records]
Statement of Interest of the United States [ECF# 27]
PB-VA-0007-0002.pdf | Detail
Date: 11/07/2016
Source: PACER [Public Access to Court Electronic Records]
Memorandum Opinion [ECF# 56] (2017 WL 963234) (W.D. Va.)
PB-VA-0007-0003.pdf | WESTLAW | Detail
Date: 03/13/2017
Source: PACER [Public Access to Court Electronic Records]
Judges Hoppe, Joel C. Court not on record [Magistrate]
PB-VA-0007-9000
Moon, Norman K. (W.D. Va.)
PB-VA-0007-0003 | PB-VA-0007-9000
Plaintiff's Lawyers Bauer, Mary C. (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Baugh, David Preston (Virginia)
PB-VA-0007-0001
Blank, Jonathan Todd (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Ciolfi, Angela A. (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Kendrick, Leslie Carolyn (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Levy-Lavelle, Patrick (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Salas, Mario David (Virginia)
PB-VA-0007-0001 | PB-VA-0007-9000
Defendant's Lawyers Baugh, Janet W. (Virginia)
PB-VA-0007-9000
Davidson, Nancy Hull (Virginia)
PB-VA-0007-9000
O'Shea, Margaret Hoehl (Virginia)
PB-VA-0007-9000
Yost, Adam John (Virginia)
PB-VA-0007-9000
Other Lawyers Bains, Chiraag (District of Columbia)
PB-VA-0007-0002
Bullock, Robert B. (District of Columbia)
PB-VA-0007-0002
Fishwick, John Palmer (Virginia)
PB-VA-0007-0002
Foster, Lisa A. (District of Columbia)
PB-VA-0007-0002
Giorno, Anthony P. (Virginia)
PB-VA-0007-0002
Heilberg, David L. (Virginia)
PB-VA-0007-9000
Johnston, Maureen (District of Columbia)
PB-VA-0007-0002
Killebrew, Paul (District of Columbia)
PB-VA-0007-0002
Lash, Karen (District of Columbia)
PB-VA-0007-0002
Moossy, Robert J. (District of Columbia)
PB-VA-0007-0002
Rosenbaum, Steven H. (District of Columbia)
PB-VA-0007-0002
Volek, Jude (District of Columbia)
PB-VA-0007-0002
Wayne, Seth (District of Columbia)
PB-VA-0007-0002

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