Peck v. Idaho Transportation Department

Citations: 156 Idaho 112; 320 P.3d 1271; 2014 WL 657980; 2014 Ida. App. LEXIS 18Docket: 40808

Court: Idaho Court of Appeals; February 21, 2014; Idaho; State Appellate Court

Original Court Document: View Document

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Raymond Scott Peck appeals the Idaho district court's decision affirming the Idaho Transportation Department’s (ITD) suspension of his commercial driver’s license (CDL) following a DUI incident. On December 2, 2009, Peck was stopped for speeding, whereupon a police officer detected signs of alcohol use. Peck refused field sobriety tests but was arrested and later tested with a breathalyzer, yielding two results of .083 and .086, which violated Idaho law. Although Peck was not driving a commercial vehicle at the time, his CDL was suspended for one year according to Idaho Code § 49-335 due to the failed breath tests.

Peck contested this disqualification at an ITD hearing, which was initially stayed pending his appeal of the administrative license suspension (ALS). The hearing officer upheld the suspension, and the district court affirmed that decision. Subsequently, the ITD hearing officer confirmed Peck’s CDL disqualification, leading to the current appeal. 

Peck argues that the disqualification violates his procedural and substantive due process rights. The review of ITD decisions is governed by the Idaho Administrative Procedures Act (IDAPA), and the appellate court independently examines the agency record without substituting its judgment for that of the agency regarding evidence weight. The court ultimately affirmed the district court's ruling on Peck's CDL disqualification.

The Court defers to agency findings of fact unless clearly erroneous, affirming that these determinations are binding even with conflicting evidence, provided they are supported by substantial and competent evidence. The Court can overturn an agency decision if findings violate statutory or constitutional provisions, exceed statutory authority, are made via unlawful procedures, lack substantial evidence, or are arbitrary or capricious. A party challenging an agency decision must show specified error and demonstrate prejudice to a substantial right. If the decision is not upheld, it will be set aside and remanded for further action. 

Penalties related to driver’s privileges for failing evidentiary testing are outlined in Idaho Code (I.C.) § 18-8002A, with additional consequences for commercial vehicle operators specified in I.C. § 49-335(2). A disqualification from operating commercial vehicles is mandated for a minimum of one year for those who refuse or fail such tests. Drivers may contest disqualifications via administrative hearings, independent of Title 18 provisions, and have the right to judicial review of adverse decisions.

Peck contends that his procedural due process rights were violated due to a lack of notice regarding disqualification provisions, arguing that his evidentiary testing lacked implied consent and breached his constitutional rights. Courts analyzing due process must consider the affected private interest, the risk of erroneous deprivation through current procedures, and the government's interest, including potential burdens of additional safeguards. The hearing officer concluded that no further notice was required beyond statutory notifications, a finding the district court upheld, indicating that due process does not necessitate informing drivers of separate CDL consequences for failing tests.

Peck asserts that he did not provide implied consent for a BAC sample due to insufficient notice about the consequences of a failed test on his CDL. The Court previously ruled that due process does not require police officers to inform drivers of the implications of a failed BAC test for CDL proceedings. Since Peck had not yet challenged his CDL disqualification, it was not subject to judicial review. The Court referenced a previous case, Platz, clarifying that a hearing officer in CDL disqualification cases must only verify the possession of a CDL and whether the driver failed an alcohol concentration test. It was established that Peck possessed a CDL and failed the alcohol test, which he contested but was upheld by both the district court and the Court.

The Court emphasized that the CDL disqualification is contingent upon the ALS determination and that Peck has no right to contest the evidentiary testing in both ALS and CDL contexts, as he had already challenged it during the ALS proceedings. Consequently, his procedural due process claim regarding notice is unfounded. Even if considered, Peck's challenge would still fail since CDL holders are presumed to know relevant laws. He received the required notifications and there’s no obligation for police to inform him of CDL consequences upon a failed evidentiary test.

Regarding substantive due process, Peck claims the CDL disqualification lacks a rational relationship to any legitimate legislative purpose, as the ALS suspension already addresses the issue. Both the U.S. and Idaho Constitutions protect against state deprivation of life, liberty, or property without due process, requiring that such actions not be arbitrary or capricious. A violation is not present if the state action has a reasonable connection to a legitimate legislative objective.

The ITD hearing officer did not rule on Peck’s substantive due process rights, and the district court determined that these rights were not violated, emphasizing the public interest in maintaining safe roadways free from intoxicated drivers. Citing Williams v. Idaho, the court noted that the removal of problem drivers through disqualification is a legislative priority for public safety. Peck argued that his CDL disqualification was arbitrary and unnecessary since he had already served his ALS suspension. However, the court found that the disqualification under I.C. § 49-335 serves a legitimate state purpose related to public safety, as it is rationally connected to preventing intoxicated driving in commercial contexts. Peck failed to provide evidence that the statute is arbitrary or that it does not align with legitimate legislative objectives. The court clarified that ALS and CDL proceedings are distinct, with different penalties reflecting the increased risks associated with commercial vehicles. Consequently, the district court's affirmation of Peck's CDL disqualification was upheld, and his request for attorney fees was denied, as he was not the prevailing party.