Defendant, Michael Jacobsma, in this case challenged a citation that was issued to him for a speeding violation under an automated traffic enforcement ordinance enacted by the City of Sioux City. Jacobsma challenged the ordinance, among other things, on constitutional grounds; more specifically that it violated due process, specifically substantive due process.
Jacobsma’s main argument was that the automated traffic enforcement ordinance created an arbitrary presumption that the vehicle’s owner was the violator of the ordinance and the only way to rebut such a presumption was for the owner to demonstrate that he or she had filed a stolen vehicle report, which he argued, created an impermissible presumption.
The City, however, argued that the infraction imposed a civil penalty. Because the infraction was a civil penalty, due process is satisfied when “there is a reasonable fit between the government interest and the mean utilized to advance that interest.” The narrow issue in this case was whether the ordinance violated Jacobsma’s due process rights when he conceded that he was the owner of the vehicle involved in the infraction, that the vehicle involved in the infraction was speeding, but offered no evidence that he was not the driver of the vehicle when the infraction occurred.
However, just as quickly as it raised this narrow issue, the Iowa Supreme Court determined that the facts underlying the case limited the scope of the constitutional challenge because Jacobsma did not deny that he was the driver and offered no evidence to substantiate that someone else was driving. He simply argued that the City’s case failed because he claimed that it was an impermissible presumption. Therefore, it considered this issue entirely academic, and as such, was not an issue properly before the Court leaving the only issue as to whether the stipulated facts were enough to impose liability on Jacobsma for the infraction.
Ultimately, the Iowa Supreme Court held that the automated traffic camera did not violate Jacobsma’s due process rights and that an inference that the registered owner was the driver of the vehicle at the time of the infraction is reasonable. Finally, the Court held that the stipulated facts in the case; i.e., Jacobsma’s admission that it was his vehicle involved in the infraction and that he was the owner of the vehicle was enough to impose liability on him as the owner. City of Sioux City v. Jacobsma (2015).
Commentary:
What can we take from this case? At this point in time, automated traffic ordinances (i.e. traffic cameras) are constitutional. The deciding factors in this case that limited Jacobsma’s constitutional challenge was the fact that he did not deny that he was driving the vehicle and he did not provide any evidence that he was not the driver of the vehicle when the infraction occurred. The Court did not comment on whether the result would have been different had Jacobsma actually argued that he was not the driver of the vehicle. So for now take notice when you drive through intersections because the cameras are watching.
