DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
152703P.pdf 11/02/2016 Gary Hughes v. City of Cedar Rapids
U.S. Court of Appeals Case No: 15-2703
U.S. District Court for the Northern District of Iowa - Cedar Rapids
[PUBLISHED] [Benton, Author, with Loken and Beam, Circuit Judges]
Civil case - Traffic cameras. In action by drivers claiming the City's use
of automated traffic cameras to ticket red-light violations violated their
fde process rights, the fundamental right to travel, Iowa Code Section
602.6101 and caused unjust enrichment to the City and the company
providing the service, the district court did not err in finding plaintiff
Hughes lacked standing as he had no injury in fact; further the court
correctly determined plaintiff Mazgaj did not have standing to assert his
wife's claim; however, plaintiff Lee's claims did establish standing as he
has the hardship of a citation and the costs of litigation; while the
district court did not err in finding Mazgaj and Hughes lacked standing,
the court never had jurisdiction over their claims and it should have
remanded their claims to the state court from which the action had been
removed; with respect to six other named plaintiffs, those drivers
established standing to bring procedural-due-process claims; however, they
failed to show a procedural due process violation as they did not show the
risk of an erroneous deprivation as a result of the procedures employed;
allegations that the administrative process provided for the tickets was a
"rubber stamp" and a "sham" were too conclusory to support their claim for
violation of their procedural-due-process rights; claims that the system
violated their substantive rights - such as the right to travel and the
Privileges and Immunities Clause - is rejected; Equal Protection claim
rejected; claim that the procedures violated Iowa Department of
Transportation rules was not ripe as that issue is pending in state
court,and the district court should dismiss without prejudice plaintiff's
state-law claims based on an alleged violation of the rules; unjust
enrichment claim rejected.