New Jersey Supreme Court Upholds License Plate Decals for Drivers Under 21 - Trautmann v. Christie, A-16-11
Tuesday, August 7, 2012
From the unanimous New Jersey Supreme Court syllabus:
"In this appeal, the Court determines the validity of Chapter 37 of the Laws of 2009, “Kyleigh’s Law.”
"New Jersey’s graduated driver’s license system (GDLS) requires a new driver to first obtain a permit and then a probationary license, before applying for a basic license. In general, holders of GDLS authorizations cannot drive between certain hours of the day, cannot drive with more than a certain number of non-parents and nondependents in the vehicle, and cannot use wireless devices. GDLS supports safety on the roadways by phasing-in new drivers’ exposure to driving tasks and environments under supervised conditions. Chapter 37 facilitates enforcement of GDLS restrictions by requiring individuals who are driving pursuant to permits or probationary licenses to display “removable, transferable, highly visible, reflective decals” on their vehicles. As applied by the New Jersey Motor Vehicle Commission, only drivers under the age of twenty-one must obtain and display the decals.
"Plaintiffs sought declaratory and injunctive relief on the grounds that Chapter 37 is preempted by the federal Driver’s Privacy Protection Act, 18 U.S.C.A. §§ 2721-2725; violates equal protection; and constitutes an unreasonable search and seizure. The trial court dismissed plaintiffs’ complaint and the Appellate Division affirmed. The panel found that the decal requirement is not preempted by the federal statute because disclosure of a person’s age group is not “personal information” under the Act; that the decal requirement does not violate equal protection because it is a rational and suitable means of furthering a legitimate and appropriate government interest; and that the decal requirement does not give rise to an unreasonable search and seizure because a driver has no
reasonable expectation of privacy in his or her age group and an officer’s examination of the decal is not a “search.” The Court granted certification. 208 N.J. 369 (2011).
HELD: The judgment is affirmed substantially for the reasons expressed in the opinion of the Appellate Division. Chapter 37 is not preempted by federal law, does not violate equal protection, and does not give rise to an unconstitutional search and seizure.
Full decision after the jump...
"In this appeal, the Court determines the validity of Chapter 37 of the Laws of 2009, “Kyleigh’s Law.”
"New Jersey’s graduated driver’s license system (GDLS) requires a new driver to first obtain a permit and then a probationary license, before applying for a basic license. In general, holders of GDLS authorizations cannot drive between certain hours of the day, cannot drive with more than a certain number of non-parents and nondependents in the vehicle, and cannot use wireless devices. GDLS supports safety on the roadways by phasing-in new drivers’ exposure to driving tasks and environments under supervised conditions. Chapter 37 facilitates enforcement of GDLS restrictions by requiring individuals who are driving pursuant to permits or probationary licenses to display “removable, transferable, highly visible, reflective decals” on their vehicles. As applied by the New Jersey Motor Vehicle Commission, only drivers under the age of twenty-one must obtain and display the decals.
"Plaintiffs sought declaratory and injunctive relief on the grounds that Chapter 37 is preempted by the federal Driver’s Privacy Protection Act, 18 U.S.C.A. §§ 2721-2725; violates equal protection; and constitutes an unreasonable search and seizure. The trial court dismissed plaintiffs’ complaint and the Appellate Division affirmed. The panel found that the decal requirement is not preempted by the federal statute because disclosure of a person’s age group is not “personal information” under the Act; that the decal requirement does not violate equal protection because it is a rational and suitable means of furthering a legitimate and appropriate government interest; and that the decal requirement does not give rise to an unreasonable search and seizure because a driver has no
reasonable expectation of privacy in his or her age group and an officer’s examination of the decal is not a “search.” The Court granted certification. 208 N.J. 369 (2011).
HELD: The judgment is affirmed substantially for the reasons expressed in the opinion of the Appellate Division. Chapter 37 is not preempted by federal law, does not violate equal protection, and does not give rise to an unconstitutional search and seizure.
Full decision after the jump...
