In the case of Jeffrey S. Amick vs. Director of Revenue (No. SC93742), decided on April 15, 2014, by the Supreme Court of Missouri, the central issue revolved around the interpretation and application of the equal protection clause in the context of driving privileges for individuals convicted of felony driving while intoxicated (DWI).
Jeffrey Amick, having been convicted of a DWI felony, faced a suspension of his driving privileges for ten years. Seeking to regain limited driving privileges, Amick’s petition was dismissed by the Circuit Court of St. Louis County, citing his ineligibility under section 302.309.3(6)(b), which disqualifies individuals with felony convictions involving motor vehicles from obtaining such privileges.
Amick appealed this decision, arguing that the statute violated the equal protection clause, specifically contrasting his situation with section 302.309.3(9), which permits DWI court graduates and participants to regain limited driving privileges. He contended that this differential treatment was unconstitutional.
The Supreme Court of Missouri employed a rational-basis review for this equal protection analysis, as the statute did not involve a suspect classification or infringe upon a fundamental right. The Court concluded that the state had a legitimate interest in public safety, particularly concerning individuals convicted of DWI. The decision to allow DWI court participants and graduates access to limited driving privileges was deemed rationally related to this interest. The Court reasoned that participants in these programs might be less likely to reoffend and thus pose a lesser risk to public safety. Furthermore, offering the opportunity for reinstatement of driving privileges could incentivize offenders to engage in treatment and avoid future DWI incidents.
The Court also addressed Amick’s argument regarding potential alternative measures, such as ignition interlock devices, to achieve the state’s public safety goals. It noted that the burden of proof to demonstrate the law’s irrationality lay with the challenger and that suggesting alternative measures did not invalidate the statute’s rational basis.
The Supreme Court affirmed the lower court’s judgment, ruling that section 302.309.3(6)(b) did not violate the equal protection clause. This case highlights the balance courts strike between individual rights and public safety concerns, and it illustrates the application of rational-basis review in equal protection claims involving non-suspect classifications and non-fundamental rights.