Garcia v. City of Willis
Supreme Court of Texas, No. 17-0713 (May 3, 2019)
Opinion by Justice Brown (linked here)
Texans will have to wait to learn whether enforcing traffic rules through the use of red-light cameras infringes an individual’s constitutional rights. The Texas Supreme Court held a plaintiff making that challenge lacked standing because he paid his fine and did not argue “he plans to violate red-light laws in the future.”
Luis Garcia filed a class action against the City of Willis, challenging the constitutionality of the Texas “Red Light Camera Statute,” chapter 707 of the Texas Transportation Code, as implemented by the City’s “Red Light Camera Ordinance.” Garcia sought equitable relief and restitution of penalties paid.
As required by the statute, the ordinance provided an “administrative adjudication hearing” for contesting civil penalties imposed on vehicle owners for violations captured by a red-light camera. Failure to timely contest liability is deemed an admission of liability and a waiver of the vehicle owner’s right to appeal. Additionally, the City’s municipal court was given “exclusive appellate jurisdiction” in cases arising under the statute. After being cited for a traffic violation apparently captured on camera, Garcia did not appeal his citation to the municipal court, and ultimately paid the fine.
In response to Garcia’s suit, the City filed a plea to the jurisdiction seeking dismissal on the grounds of governmental immunity and failure to exhaust administrative remedies. The district court denied the plea, and the City filed an interlocutory appeal. The Beaumont Court of Appeals reversed and rendered judgment for the City, without reaching the constitutional issue. The court held Garcia’s failure to exhaust the administrative process was fatal, depriving the district court of jurisdiction.
The Texas Supreme Court accepted review to consider: “(1) whether the trial court lacked jurisdiction because Garcia failed to exhaust administrative remedies … and (2) whether the ultra-vires exception to governmental immunity applies because the city allegedly … use[d] improperly installed and operated cameras.” However, when the State of Texas filed an amicus brief arguing lack of standing as an alternative ground for affirming the dismissal of Garcia’s claims, the Supreme Court agreed with the State. The Court explained: “Garcia may earnestly believe that red-light cameras are unconstitutional and bad public policy. But, having paid his fine without arguing he will potentially break the law in the future, he has no particularized interest in the issue from a member of the public at large.” Nor could he obtain standing by the failure of other class members to pay their fines. Because the named plaintiff lacked “an individual and justiciable interest in the case … [w]hether any other class member has standing is irrelevant.”
The Court further held the City’s governmental immunity barred Garcia’s claim for reimbursement of his fine. Although the Court recognized “a narrow exception to immunity when a plaintiff seeks reimbursement of an allegedly unlawful tax, fee, or penalty,” that exception applies only if the payment was made “involuntarily and under duress.” Garcia’s failure to pursue an administrative appeal “that would have entitled him to an automatic stay of the enforcement of his fine” was fatal to his claim of duress. That failure also derailed his claim of an unconstitutional taking; although the Court did not reach the question whether a person making constitutional challenges is “generally required to exhaust his administrative remedies,” it held following the available procedure was a necessary step here because it could have resulted in cancellation of the fine, which would have mooted the takings claim.
In the end, the Court affirmed the judgment of the appellate court, but for very different reasons.