Court: Supreme Court of Missouri; July 16, 2013; Missouri; State Supreme Court
The driver, Robert Brian Bone, challenged the constitutional validity of Missouri statutes sections 302.700 and 302.755.1, which disqualify individuals convicted of alcohol-related offenses from operating commercial vehicles for at least one year. Following a trial court ruling that these statutes violated the U.S. Constitution based on the Supreme Court case NFIB v. Sebelius, the court reinstated Bone's driving privileges, including his commercial driver’s license (CDL). However, this Court reversed that judgment, affirming the statutes' validity.
Bone was arrested for impaired driving after failing sobriety tests and registering a blood alcohol level of .096%. His license was suspended under section 302.505 due to probable cause of driving under the influence. Bone filed a petition for a trial de novo, contesting the suspension and alleging due process violations related to multiple statutes, including sections 302.5002, 302.700, and 302.755, asserting they lacked rational basis and failed to provide proper notification regarding the consequences of chemical testing on his CDL eligibility.
During the trial, Bone argued that the statutes were unconstitutional as they coerced compliance with federal funding conditions, referencing the NFIB decision which found similar coercion regarding Medicaid expansion. He claimed the statutes were improperly tied to federal highway funding requirements, which influenced the state’s blood alcohol regulations. Bone sought judicial notice of NFIB and relevant federal laws to support his claims against the constitutionality of the statutes in question.
Federal law incentivizes state compliance with specific regulations by providing federal highway funds, with penalties for noncompliance. In this case, the court found probable cause to arrest Driver for an alcohol-related offense due to a blood-alcohol concentration of .08% or higher. Additionally, the trial court ruled that Missouri statutes 302.500 and 302.700 violated the U.S. Constitution as per the precedent set in NFIB, leading to the removal of Driver’s suspension from his record and the reinstatement of his driving privileges, including his Commercial Driver's License (CDL). The court did not address Driver's other claims regarding due process and equal protection violations. The Department of Revenue (DOR) appealed the decision.
Regarding the standard of review, Missouri's Constitution grants exclusive jurisdiction to the court for appeals involving the constitutional validity of state statutes. Such challenges are reviewed de novo, with a presumption of validity unless a clear constitutional violation is demonstrated.
DOR argued that Driver waived his NFIB-related constitutional argument by not raising it promptly. However, Driver presented this argument during the August 2012 hearing, following the Supreme Court's NFIB ruling, and DOR did not object at that time. As a result, Driver's argument was treated as an amendment to his pleadings under Supreme Court Rule 55.33(b), allowing for the determination of issues not explicitly raised if there is no objection. Consequently, Driver's argument under NFIB was deemed timely and properly before the trial court.
The trial court's determination that Section 302.700 violated the United States Constitution was erroneous. Driver argued that various state statutes, including a reduction of the legal blood-alcohol concentration limit and suspension of commercial driver's licenses (CDLs) for first alcohol-related offenses, were coerced by federal legislation threatening to withhold highway funding. However, the NFIB case, which deemed coercive certain federal conditions on state funding, does not support Driver's claim regarding state law violations. The NFIB ruling did not address the validity of state laws enacted in response to such federal pressures, nor does it assert that state statutes can be deemed unconstitutional under the Spending Clause.
Additionally, Driver's claims regarding due process and equal protection were found to lack merit. Limited arguments and evidence presented in the trial court did not establish any violation of these rights, and the court found no supporting findings on these claims. Consequently, this Court reviewed the matter de novo and concluded that Driver's arguments were insufficient.
The judgment against Section 302.700 is reversed, as Driver failed to prove its unconstitutionality. The court also noted potential confusion regarding the trial court's findings related to Section 302.500, which likely stemmed from a clerical error since it is merely a definitional section and does not implicate the NFIB decision. The Court clarified that it would focus on the constitutionality of Section 302.700. Lastly, the Spending Clause is acknowledged, asserting Congress's power to tax and spend, but does not affect the validity of state legislation. All claims presented by Driver were ultimately denied, and the judgment of the trial court was reversed.
