University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Thomas v. Haslam CJ-TN-0008
Docket / Court 3:17-cv-00005 ( M.D. Tenn. )
State/Territory Tennessee
Case Type(s) Criminal Justice (Other)
Public Benefits / Government Services
Special Collection Fines/Fees/Bail Reform (Criminalization of poverty)
Post-WalMart decisions on class certification
Attorney Organization Civil Rights Corps
Case Summary
On January 4, 2017, indigent driver’s license holders filed this class action lawsuit in the U.S. District Court for the Middle District of Tennessee against the Tennessee Department of Safety and Homeland Security under 42 U.S.C. §1983. The plaintiffs alleged that the Tennessee statute at issue ... read more >
On January 4, 2017, indigent driver’s license holders filed this class action lawsuit in the U.S. District Court for the Middle District of Tennessee against the Tennessee Department of Safety and Homeland Security under 42 U.S.C. §1983. The plaintiffs alleged that the Tennessee statute at issue automatically revoked driver’s licenses of people who failed to pay court fines, costs, or litigation taxes within one year, without consideration of their ability to pay. The plaintiffs, represented by both public interest and private lawyers, sought to enjoin the defendants from revoking driver’s licenses and to reinstate all revoked licenses after waiving the reinstatement fees. They also asked for a declaration that the Tennessee statute violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment.

This is second of two cases challenging Tennessee’s practice of rescinding the driver’s licenses of those who are unable to pay the fines without consideration of their indigence. In the companion case, (here in the Clearinghouse), Robinson v. Purkey, a preliminary injunction was granted prohibiting license suspensions for failure to pay fines unless the legislature enacts a statute requiring inquiry as to the defendant's ability to pay--the court required reinstatement of licenses suspended for nonpayment and to waive reinstatement fees.

The plaintiffs moved for a class certification on January 5, 2017, which was met with defendants’ motion to dismiss on March 3, 2017. The plaintiffs then filed a renewed motion for a class certification and a motion for summary judgment on August 18, 2017.

On October 10, 2017, co-defendants Governor of Tennessee and Attorney General of Tennessee were dismissed without prejudice. The only remaining defendant, Tennessee Department of Safety and Homeland Security, filed a motion for summary judgment on November 6, 2017.

On March 26, 2018, District Judge Aleta Trauger denied the defendant’s motion to dismiss and granted the plaintiffs’ motion for class certification. Judge Trauger certified the class as “[a]ll persons whose Tennessee driver’s licenses have been or will be revoked pursuant to the Statute [Tenn. Code Ann. § 40-24-105(b)] and who, at the time of the revocation, cannot or could not pay Court Debt due to their financial circumstances.” 303 F. Supp. 3d 585.

On July 2, 2018, Judge Trauger granted the plaintiffs’ motion for summary judgment and denied the defendant’s motion for summary judgment. The court held that revocation of indigent drivers' licenses for failure to timely pay court debts, without inquiry into drivers' ability to pay, violated their due process and equal protection rights. 329 F. Supp. 3d 475.

Following the judgment, the defendant appealed the case to the Sixth Circuit on July 25, 2018. Judge Trauger granted the defendant a partial stay pending appeal on July 31, 2018. As of February 15, 2019, the case pending on appeal.

On May 22, 2019, the Governor of Tennessee signed into law HB0839, which amended the statute to allow an exception for indigence. Because the amended statute essentially granted the relief that the plaintiffs had sought in this case, they moved to dismiss their claims as moot. Accordingly, the Sixth Circuit dismissed the state's appeal on September 12, 2019, vacated the district court's judgment, and remanded with instructions to dismiss. The district court dismissed the case on September 30, 2019.

As of August 7, 2020, the only outstanding issue is the question of attorneys' fees and costs.

Sichun Liu - 02/15/2019
Averyn Lee - 02/23/2019


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
Defendant-type
Law-enforcement
General
Drivers Licenses
Fines/Fees/Bail/Bond
Poverty/homelessness
Plaintiff Type
Private Plaintiff
Causes of Action 42 U.S.C. § 1983
Declaratory Judgment Act, 28 U.S.C. § 2201
Defendant(s) Tennessee Department of Safety and Homeland Security
Plaintiff Description All persons whose Tennessee driver’s licenses have been or will be revoked pursuant to the Statute [Tenn. Code Ann. § 40-24-105(b)] and who, at the time of the revocation, cannot or could not pay Court Debt due to their financial circumstances.
Indexed Lawyer Organizations Civil Rights Corps
Class action status sought Yes
Class action status granted Yes
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Declaratory Judgment
Source of Relief Litigation
Filed 01/04/2017
Case Ongoing Yes
Case Listing CJ-TN-0010 : Robinson v. Purkey (M.D. Tenn.)
Additional Resources
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  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
  Tennessee: State-wide Driver's License Suspensions
http://www.civilrightscorps.org/
Date: Oct. 16, 2018
By: Civil Rights Corps
[ Detail ] [ External Link ]

Docket(s)
3:17-cv-00005 (M.D. Tenn.)
CJ-TN-0008-9000.pdf | Detail
Date: 01/22/2020
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
CJ-TN-0008-0001.pdf | Detail
Date: 01/04/2017
Source: PACER [Public Access to Court Electronic Records]
Memorandum Signed by Judge Trauger [ECF# 93] (303 F.Supp.3d 585) (M.D. Tenn.)
CJ-TN-0008-0002.pdf | WESTLAW| LEXIS | Detail
Date: 03/26/2018
Source: PACER [Public Access to Court Electronic Records]
Memorandum [ECF# 113] (329 F.Supp.3d 475) (M.D. Tenn.)
CJ-TN-0008-0003.pdf | WESTLAW| LEXIS | Detail
Date: 07/02/2018
Source: PACER [Public Access to Court Electronic Records]
On Appeal from the United States District of Tennessee [Ct. of App. ECF# 47-1] (776 Fed.Appx. 910)
CJ-TN-0008-0004.pdf | WESTLAW| LEXIS | Detail
Date: 09/12/2019
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 138] (M.D. Tenn.)
CJ-TN-0008-0005.pdf | Detail
Date: 09/30/2019
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Donald, Bernice Bouie (W.D. Tenn., Sixth Circuit) show/hide docs
CJ-TN-0008-0004
Rogers, John M. (Sixth Circuit) show/hide docs
CJ-TN-0008-0004
Thapar, Amul Roger (E.D. Ky., Sixth Circuit) show/hide docs
CJ-TN-0008-0004
Trauger, Aleta Arthur (M.D. Tenn.) show/hide docs
CJ-TN-0008-0002 | CJ-TN-0008-0003 | CJ-TN-0008-0005 | CJ-TN-0008-9000
Plaintiff's Lawyers Cole, Jonathan Jacob (Tennessee) show/hide docs
CJ-TN-0008-9000
Dharia, Premal T. (District of Columbia) show/hide docs
CJ-TN-0008-9000
Fajana, Francisca (New York) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Gerstein, Charles L. (District of Columbia) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Krugman, Edward P. (District of Columbia) show/hide docs
CJ-TN-0008-9000
Lau, Theresa (New York) show/hide docs
CJ-TN-0008-9000
Patterson, Lori H. (Tennessee) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Spickler, Josh (Tennessee) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Tasheff, Petra T. (New York) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Wang, Jonas (District of Columbia) show/hide docs
CJ-TN-0008-9000
White, Matthew G. (Tennessee) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Wilner, Claudia (New York) show/hide docs
CJ-TN-0008-0001 | CJ-TN-0008-9000
Defendant's Lawyers Campbell, Andrew B. (Tennessee) show/hide docs
CJ-TN-0008-9000
Dix, Katherine (Tennessee) show/hide docs
CJ-TN-0008-9000
Meyer, Michael Alan (Tennessee) show/hide docs
CJ-TN-0008-9000
Ohlman, Sara (Tennessee) show/hide docs
CJ-TN-0008-9000
Rieger, Alexander Stuart (Tennessee) show/hide docs
CJ-TN-0008-9000
Sutherland, Pamela Kirkpatrick (Arizona) show/hide docs
CJ-TN-0008-9000

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