Jane Doe was driving and arrived at a traffic checkpoint operated by the Buffalo Police Department. Because she lacked a harness for her children's booster seats, she was assessed eight points on her driver’s license, $446 in fines and $450 for a Driver Responsibility Assessment. During this time, Ms. Doe was a full time student with no income. BTVA refused to accept partial payments or provide a payment plan. Unable to pay, her learner’s permit was suspended. In 2018, she used her tax refund to pay her traffic tickets and reinstate her permit.