Knutson v. Village of Lakemoor, No. 18-3729 (7th Cir. 2019)Annotate this Case
The Seventh Circuit affirmed the district court's dismissal of a class action suit challenging the red light camera program of the Village of Lakemoor. Plaintiffs alleged that the violation notices they received were invalid because the notices lack a proper municipal code citation, and that Lakemoor denied them due process by limiting the defenses that can be asserted before a hearing officer to contest a violation.
The court held that the process that plaintiffs received was constitutionally sufficient and therefore they have failed to state a federal due process claim. The court also held that plaintiffs' argument that the violation notices were void ab initio failed as a matter of law, because the "specific reference" provision was directory rather than mandatory. Accordingly, plaintiffs' unjust enrichment claim also failed.