Clark v. State of Minnesota Department of Public Safety and Driver and…

Background

Lonnie Kevin Clark, proceeding without a lawyer, sued the State of Minnesota Department of Public Safety and Driver and Vehicle Services, Dawn Olson, Andrea Fasbender, and Leigh, Agent 2860. Clark challenged the continued revocation of his driver’s license and the reinstatement requirements imposed after his related criminal case was dismissed. He sought $80,000 in damages and waiver of the reinstatement requirements.

Clark’s license had been administratively revoked in 2003 under Minnesota’s implied-consent law after his arrest for driving while impaired. A Hennepin County District Court later dismissed the criminal case because the state violated his speedy-trial right. Driver and Vehicle Services nevertheless required Clark to pay a $680 reinstatement fee and complete other requirements, including written tests, a new permit application, and a physician’s statement. The agency explained that the civil administrative revocation was separate from the criminal case.

Defendants’ Motion and Extension Request

The defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Rule 12(b)(1) concerns whether the court has authority to hear a case, while Rule 12(b)(6) concerns whether the complaint adequately states a legal claim. Clark had previously received two extensions to respond. The court denied his fourth request for an additional 30 to 60 days because he did not show new circumstances supporting the request.

State Immunity

The court held that the Eleventh Amendment barred Clark’s claims against the state agency. It also held that the amendment barred his claims for money damages against Olson, Fasbender, and Leigh because the court understood Clark to be suing those defendants only in their official capacities. The court noted that state officials may sometimes be sued in their official capacities for prospective—not backward-looking—injunctive relief alleging an ongoing violation of federal law, but Clark’s claims against the agency were barred in their entirety and the money-damages claims against the officials were barred.

Due Process Claim

The court rejected Clark’s argument that dismissal of the criminal case invalidated the license revocation and reinstatement fee. Minnesota law provides separate processes for administrative license revocation based on probable cause and a failed alcohol test, and revocation based on a criminal conviction. Clark’s revocation resulted from the administrative process, not from a conviction. Therefore, the dismissal of the criminal case did not affect the revocation, fee, or reinstatement requirements.

The court also stated that, to the extent Clark challenged the constitutionality of Minnesota’s implied-consent revocation process itself, the United States Supreme Court had upheld this type of process. To the extent Clark sought to challenge the original revocation, the court held that he had not timely sought the available administrative or judicial review, making the revocation order a final administrative decision entitled to preclusive effect.

Excessive-Fines Claim

The complaint could also be read to claim that the $680 reinstatement fee violated the Eighth Amendment’s Excessive Fines Clause. The court assumed without deciding that the fee qualified as a fine covered by that clause. It nevertheless held that Clark pleaded no facts showing that the fee was grossly disproportionate to the seriousness of driving while impaired. The court dismissed this claim. It also stated that continued license revocation was not a payment in money or property and therefore did not constitute a fine under the authorities it cited.

Disposition

The court ordered that:

Judge Eric C. Tostrud directed that judgment be entered accordingly.