Worthy v. City of Phenix City, Alabama

Court: 11th Circuit
Case Number: 930 F.3d 1206
Decision Date: July 18, 2019
Case Type: Municipal Courts
After receiving authorization from the Alabama legislature, the City of Phenix City adopted an ordinance permitting the city to install and operate red light cameras. The operating scheme would have videos and photos sent to a private company for review which would, in turn, be sent to a Phenix City police officer who would have discretion to issue a citation. The motorist receiving the citation would be liable for a $100 civil penalty, which were not reported on the motorist's driving record. Motorists could contest the penalty in an administrative hearing, which would be held before a non-judicial officer. Appellants received citations through this process and were found in violation after going before the hearing officer.

None of the appellants chose to appeal to a circuit court because the court filing fees would be larger than the civil fine. Instead, appellants chose to file a lawsuit alleging that the ordinance violated both the federal and state constitution because sufficient processes to challenge the penalties were not available. The city and the company moved to dismiss and the district court agreed that the appellants did not have standing to challenge the ordinance. The Eleventh Circuit, however, held that the appellants did have standing to bring a damages claim but they lacked standing to seek injunctive relief. Additionally, the court held that the penalty was civil and the motorists were not deprived of their First Amendment rights to petition the courts for redress. Finally, the court held that the ordinance did not deprive the motorists of their due process rights.