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Rodney E. Elliott v. City of Wheat Ridge Wheat Ridge Municipal Court Named as City of Wheat Ridge Municipal Court Charles J. Rose, Judge Randall J. Davis, Judge David Dawson, Patrolman Darin Schanker, City Attorney Dan Wilde, Mayor Vance Edwards, Councilperson Jean Fields, Councilperson Ken Siler, Councilperson Tony Solano, Councilperson Donald R. Eafanti, Councilperson Rae Jean Behm, Councilperson Dennis Hall, Councilperson and Claudia Worth, Councilperson
Citation: 49 F.3d 1458Docket: 94-1430
Court: Court of Appeals for the Tenth Circuit; April 7, 1995; Federal Appellate Court
Rodney E. Elliott, the plaintiff-appellant, contested a speeding citation issued by the City of Wheat Ridge and its officials, including judges and a city attorney. He asserted that his conviction violated his due process rights under the Fifth, Sixth, Seventh, and Fourteenth Amendments, claiming the ordinance under which he was convicted was unconstitutional. Elliott sought a jury trial and appointed counsel, both of which were denied by the municipal court. The Tenth Circuit Court of Appeals reviewed the district court's granting of motions to dismiss and for summary judgment in favor of the defendants. The court applied a de novo standard of review, finding that Elliott's allegations did not raise genuine issues of material fact, thus entitling the appellees to judgment as a matter of law. The court noted that Colorado had decriminalized minor traffic violations, classifying them as civil offenses, a scheme upheld by the Colorado Supreme Court and consistent with similar rulings in other states. Elliott's conviction stemmed from a valid City ordinance enacted under this Colorado statutory scheme. Elliott argued that the ordinance was unconstitutional for not providing a right to a jury trial. While the Sixth Amendment guarantees a jury trial in criminal cases through the Fourteenth Amendment, this right is limited to cases classified as criminal. The Supreme Court has established that petty crimes, typically those with a maximum sentence of six months or less, do not require a jury trial. Thus, the determination of whether an offense is civil or criminal hinges on the potential punitive measures involved. An arrest and imprisonment or a significant fine triggers the rights of a criminal defendant, even if the legislature classifies the act as non-criminal, as established in Brown v. Multnomah County Dist. Court. Oregon's attempt to decriminalize driving under the influence was unsuccessful. Minor speeding violations with small fines can be classified as civil infractions, negating the Sixth Amendment right to a jury trial, as shown in Blanton v. City of North Las Vegas. Mr. Elliott's claim for appointed counsel was properly denied since this right applies only when a defendant faces jail time, per Scott v. Illinois. The Seventh Amendment right to a jury trial does not extend to state civil proceedings, supported by Eilenbecker v. District Court of Plymouth County. Elliott's claims of due process violations under the Fifth and Fourteenth Amendments were found unsubstantiated, as he did not identify any specific liberty or property interest violated by the Appellees. Additionally, his RICO claim lacked a plausible basis, leading to the affirmation of the district court's summary judgment. The appellate panel concluded that oral argument was unnecessary for this appeal, and thus the case was submitted without it. The district court's Order granting summary judgment is affirmed.