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Thomas F. Worthy, Et Alv.The City Of Phenix City, Alabama, Et Al

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.17-14718
DecidedJuly 18, 2019
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilCivil RightsConstitutional LawDue ProcessSection 1983Administrative LawVacaturRemand
Case Summary

Thomas Worthy, James Adams, and Willcox-Lumpkin received citations under Phenix City’s red-light-camera ordinance. The ordinance imposed a one-hundred-dollar civil penalty and provided an administrative hearing followed by judicial review. The plaintiffs argued that the system imposed criminal punishment without adequate procedural safeguards and that the city and its private camera contractor conspired to violate their constitutional rights. The district court dismissed for lack of standing. The Eleventh Circuit held that the plaintiffs had standing to pursue damages because they alleged injury from the civil penalties, but lacked standing to seek an injunction because they did not show a threat of future harm. The court nevertheless held that the complaint failed to state a federal constitutional claim. The ordinance imposed civil, not criminal, penalties, and its hearing and review procedures were constitutionally sufficient. The court vacated the district court’s reasoning and remanded for an amended dismissal consistent with those holdings, leaving the state-law claims for the district court.

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