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Case Name Mendoza v. Garrett CJ-OR-0001
Docket / Court 3:18-cv-01634-HZ ( D. Or. )
State/Territory Oregon
Case Type(s) Criminal Justice (Other)
Public Benefits / Government Services
Special Collection Fines/Fees/Bail Reform (Criminalization of poverty)
Attorney Organization Legal Services/Legal Aid
Case Summary
On September 7, 2018, five Oregon residents filed this class-action lawsuit against members of the Oregon Department of Transportation, the Oregon Transportation Commission, and the Oregon Department of Motor Vehicles. The plaintiffs, represented by the Oregon Law Center, sued the defendants under 4 ... read more >
On September 7, 2018, five Oregon residents filed this class-action lawsuit against members of the Oregon Department of Transportation, the Oregon Transportation Commission, and the Oregon Department of Motor Vehicles. The plaintiffs, represented by the Oregon Law Center, sued the defendants under 42 U.S.C. §1983. They alleged that Oregon’s statewide policy of suspending drivers licenses of Oregon residents who accrued unpaid traffic fines without allowing those individuals the opportunity to demonstrate an inability to pay was a violation of those individuals’ Fourteenth Amendment Rights to due process and equal protection. The plaintiffs sought injunctive relief and attorney’s fees. This case was initially assigned to Judge Anna Brown on September 10, 2018, but was re-assigned to Judge Marco Hernandez on September 14, 2018.

In the first complaint, the plaintiffs consisted of five Oregon residents who had their licenses suspended as a result of unpaid traffic debt. All alleged they were unable to pay these fines because of their individual economic situations. The plaintiffs filed an amended complaint on November 6, 2018. In this complaint, they added a new plaintiff: a Washington resident who had his license suspended in Oregon.

The plaintiffs moved for a preliminary injunction on September 7, 2018. In their motion, they asked for the plaintiffs and all others in their class to have their license suspensions for nonpayment removed. They also asked that plaintiffs and everyone else in their class receive the opportunity to demonstrate inability to pay before the defendants suspend their licenses again. Judge Hernandez rejected this motion on December 12, 2018, stating in his opinion that the plaintiffs failed to demonstrate a likelihood of success on their claims. 358 F.Supp.3d 1145

Although the plaintiffs filed this lawsuit as a class action suit, for unknown reasons the plaintiffs submitted an unopposed motion to withdraw their class certification request on January 11, 2019. This motion was granted on January 14, 2019.

The plaintiffs filed a second amended class action complaint on February 25, 2019, adding another Oregon resident as a plaintiff. On March 1, 2019, the defendants sought to dismiss the complaint for lack of jurisdiction and for failure to state a claim. Holding that the court had jurisdiction but the plaintiffs failed to state a claim, the court granted the motion to dismiss on May 16, 2019. Relying on the same legal analysis and discussion found in the opinion denying preliminary injunction, the court concluded that the plaintiffs failed to state a claim “because as a matter of law, the challenged statutes do not implicate a fundamental constitutional right, do not implicate a suspect classification, and are rationally related to a legitimate state interest.” 2019 WL 2251290.

The plaintiffs appealed this case on June 11, 2019 (docket number 19-35506); this case is ongoing.

Sarah Reasoner - 01/27/2019
Bogyung Lim - 06/08/2020


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
Defendant-type
Transportation
General
Drivers Licenses
Fines/Fees/Bail/Bond
Poverty/homelessness
Plaintiff Type
Private Plaintiff
Causes of Action 42 U.S.C. § 1983
Defendant(s) Department of Motor Vehicles
Oregon Department of Transportation
Oregon Transportation Commission
Plaintiff Description Oregon residents whose licenses have been suspended on the basis of unpaid traffic fines, which they allege they cannot afford to pay.
Indexed Lawyer Organizations Legal Services/Legal Aid
Class action status sought Yes
Class action status granted No
Filed Pro Se No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Filed 09/07/2018
Case Ongoing Yes
Additional Resources
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  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
Docket(s)
3:18-cv-01634-HZ (D. Or.)
CJ-OR-0001-9000.pdf | Detail
Date: 01/14/2019
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint [ECF# 1]
CJ-OR-0001-0001.pdf | Detail
Date: 09/07/2018
Source: PACER [Public Access to Court Electronic Records]
Amended Complaint [ECF# 38]
CJ-OR-0001-0002.pdf | Detail
Date: 10/16/2018
Source: PACER [Public Access to Court Electronic Records]
Order Denying Motion for Prelim. Injunction [ECF# 40] (2018 WL 6528011) (D. Or.)
CJ-OR-0001-0003.pdf | WESTLAW | Detail
Date: 12/12/2018
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Hernandez, Marco Antonio (D. Or.) show/hide docs
CJ-OR-0001-0003 | CJ-OR-0001-9000
Plaintiff's Lawyers Dennis, Jonathan M (Oregon) show/hide docs
CJ-OR-0001-0001 | CJ-OR-0001-0002 | CJ-OR-0001-9000
Englander, Beth Shara (Oregon) show/hide docs
CJ-OR-0001-0001 | CJ-OR-0001-0002 | CJ-OR-0001-9000
Fox, Emily Teplin (Oregon) show/hide docs
CJ-OR-0001-0001 | CJ-OR-0001-0002 | CJ-OR-0001-9000
Heilman, Kelsey McCowan (Oregon) show/hide docs
CJ-OR-0001-0001 | CJ-OR-0001-0002 | CJ-OR-0001-9000
Samuelson, Marisa Antonia (Oregon) show/hide docs
CJ-OR-0001-0001 | CJ-OR-0001-0002 | CJ-OR-0001-9000
Defendant's Lawyers Andrews, Beth (Oregon) show/hide docs
CJ-OR-0001-9000
Forzley, Sadie (Oregon) show/hide docs
CJ-OR-0001-9000
Hammond, G. Frank (Oregon) show/hide docs
CJ-OR-0001-9000
Stineman, Renee R. (Oregon) show/hide docs
CJ-OR-0001-9000

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