Plaintiff’s Lawsuit Against Commissioner of Department of Motor Vehicles Barred by State’s Sovereign Immunity; Plaintiff Failed to Prove Any Exceptions Applied
by
Joseph C. Maya on Jan. 23, 2024
Summary: In a criminal law matter, the Superior Court of Connecticut, Judicial District of Fairfield at Bridgeport dismissed a plaintiff’s action against the defendant Commissioner of the Department of Motor Vehicles (DMV), because she was barred under sovereign immunity doctrine from bringing suit.
Case Background
This case arose from an incident that occurred on or about July 11, 2006. The plaintiff was arrested for operating a motor vehicle while under the influence (OMVUI) of alcohol in violation of General Statutes § 14-227a, and she refused to submit to an alcohol chemical test. She pled guilty to this charge, and in light of two previous OMVUI convictions, her license was suspended for a year and she would be required to install an interlocking ignition device (IID) in her vehicle.
The plaintiff received a revised suspension notice from the DMV stating her license would instead be suspended for three years because of her refusal to submit to the chemical test. In addition, the plaintiff would not be able to make use of the IID. See General Statutes § 14-227b(i)(3)(C).
The plaintiff filed motions with the court, asking it to enjoin the defendant from suspending her license beyond the initial one-year period. The plaintiff argued that the defendant exceeded his statutory authority and, as such, violated her constitutional rights. In its motion to dismiss, the defendant countered that the court did not have subject matter jurisdiction because of the state’s sovereign immunity. He pointed out that the plaintiff did not seek declaratory or injunctive relief “based on a substantial claim that the state or its officials have violated [her] constitutional rights or that the state or its officials have acted in excess of their statutory authority.”
Sovereign Immunity Doctrine
Sovereign immunity doctrine holds that a State cannot be sued unless it authorizes or consents to suit. There are only three statutory exceptions to this rule: waiver, violation of a plaintiff’s constitutional right by a state official, and action in excess of a state official’s statutory authority which violates a plaintiff’s right. If the second exception is asserted, State action will survive strict scrutiny analysis only if it is narrowly tailored to serve a compelling state interest.
In this case, the Superior Court found “little dispute” that highway safety is a compelling state interest and that the increased suspension and IID refusal was “both reasonable and necessary to achieve the goal of protecting the public safety.” Therefore, the Court found that the plaintiff’s constitutional rights were not violated.
Regarding the third exception, the DMV Commissioner has very broad discretion “to oversee and control the operation of motor vehicles generally.” Public policy concerns underpinning our motor vehicle laws center on the protection of the lives and property of Connecticut’s citizens. The legislature has also recognized the heavy burden placed on those convicted of OMVUI “in a society dependent on automotive transportation.” The use of IIDs helps alleviate these burdens, but it is a privilege of limited application, which does not encompass suspensions based on refusing to submit to an alcohol chemical test.
In this case, the Superior Court found that the defendant “clearly” had statutory authority to impose the three-year suspension and refused the plaintiff’s request to use an IID. Therefore, because the plaintiff failed to establish the applicability of either exception, the Superior Court held her action was barred by the State’s sovereign immunity.
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