Booker v. The City of Saint Paul, No. 13-2747 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983 against the City, challenging the state's vehicle forfeiture proceeding under Minnesota Stat. 169A.63, Subdiv. 8(b). After looking at the three Mathews v. Eldridge factors, the court concluded that the City's current process - allowing those affected by vehicle forfeiture to request a judicial determination if they believe the forfeiture was erroneous - was sufficient to satisfy due process. In regards to plaintiff's Fourth Amendment claim, his vehicle was lawfully subject to forfeiture, and given his conviction for a fourth DWI, he was not entitled to get it back. Therefore, even if there hypothetically could have been a prolonged seizure had plaintiff requested a judicial determination within thirty days, he cannot show that he suffered any harm from the City's retention of his vehicle because the City was then the rightful owner. Accordingly, the court affirmed the district court's grant of summary judgment to the City.
Court Description: Civil Case - civil rights. Following Booker's arrest for fourth-offense DWI and seizure of his vehicle under Minn. Stat. sec. 169A.63, Subdiv 3, Booker challenged the constitutionality of the subsequent forfeiture of his vehicle. District court's grant of summary judgment on claims of due process and Fourth Amendment violations is affirmed. Statute's notice and 30-day demand for judicial determination comports with due process. Booker cannot complain about delay because he sat on his rights for seven months before requesting a hearing; risk of erroneous deprivation is minimal; and government's interest is substantial. Booker cannot show harm from the city's retention of his vehicle because City was then rightful owner.
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