In misdemeanor and felony cases, Tennessee automatically revoked a person’s driver’s license if they failed to pay court fines and fees one year after they were imposed. An individual’s indigence was not considered prior to revocation. A person regained the temporary right to drive only after paying all of their outstanding court debt and substantial reinstatement fees. From July 1, 2012 to June 1, 2016, Tennessee Department of Safety and Homeland Security (TDSHS) revoked over 146,000 driver’s licenses for failure to pay court fines and fees. Fewer than 11,000 licenses were reinstated.
The Federal District court ruled that a Tennessee statute that mandates the revocation of driver’s licenses for unpaid fines and fees is unconstitutional because it does not provide an exception from revocation for debtors whose failure to pay is based solely on their indigence. By revoking the driver’s licenses of people who could not afford to pay their court debt, the state imposed an additional sentence on people who were poor that people with financial resources were not subject to.
Class Certification granted: All persons whose Tennessee driver’s licenses were revoked or will be revoked pursuant to statute, at the time of revocation, who could not pay Court debt due to financial circumstances.
Summary Judgment: Tennessee Statute violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment.
No rational basis for Tennessee’s revocation scheme: The court applied a rational basis review with heightened scrutiny, considering if a scheme without an indigence exception was rational. The Court found that the revocation of the driver’s licenses of an indigent debtor is counterproductive to the legitimate purpose of collecting the underlying debt. There was no rational basis for revoking the driver’s license of an indigent debtor, especially when the consequence of revocation was to exacerbate the debtor’s poverty.
Debtor entitled to pre-revocation hearing on his ability to pay: Fourteenth Amendment requires due process before a license is revoked. Debtor facing revocation of license should be given notice and a determination related to his indigence.
Remedy: TDSHS is prohibited from revoking drivers’ licenses for unpaid court fines and fees unless and until the State lawfully adopts a process for providing an exception to revocation based on inability to pay.
Commissioner of TDSHS is ordered to submit a plan, within 60 days, for the reinstatement of revoked licenses. In the meantime, failure to pay reinstatement fees or court debt should not be used as reasons by TDSHS to prevent reinstatement of a driver’s license.
Tennessee filed a notice of appeal. Case is pending before the Sixth Circuit.