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Idris v. City of Chicago, 552 F.3d 564 (7th Cir. 2009)

TRAFFIC VIOLATIONS

Federal Circuit Courts of Appeals

Idris v. City of Chicago, No. 08-1363 (7th Cir. Jan. 5, 2009).

OVERVIEW: The city's automated red light program did not violate the constitutional principles of equal protection and due process because there is no fundamental right being infringed upon by the city's program, and the program is rationally related to the legitimate government interests of deterring traffic violations and promoting traffic safety.

SUMMARY: Plaintiffs challenged the validity of the city's implementation of a program that uses automated cameras to catch vehicles in the act of entering intersections against red traffic lights. Specifically, the plaintiffs claimed that the city's program violated the equal protection and due process clauses of the Illinois and U.S. Constitutions. The district court dismissed the plaintiffs' claims for failing to state a claim, and the Seventh Circuit Federal Court of Appeals affirmed the district court's decision. The appeals court determined that the plaintiffs' substantive due process claim was “a dud” because there is no fundamental right to run red lights or avoid being seen by a camera on a public street. In addition, the interest at stake - a $90 fine for a traffic violation - is too modest to be considered a fundamental right. The appeals court further determined that it is rational to fine the vehicle owner and, even though the program has the effect of raising revenue for the city, it also has the effect of discouraging traffic violations, which means that the city's ordinance is rationally related to a legitimate government interest.