Amini v. Dept. of Motor Vehicles CA4/1

California Court of Appeal·Decided August 25, 2026·No. D085964·Unpublished

Opinion

Filed 8/25/26 Amini v. Dept. of Motor Vehicles CA4/1

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

MEHDI AMINI, D085964

Plaintiff and Respondent, (San Diego Super. Ct. No.

v. 37-2024-00009445-CU-WM-CTL)

DEPARTMENT OF MOTOR VEHICLES,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of San Diego County, Wendy M. Behan, Judge. Request for judicial notice is granted in part and denied in part. Reversed with directions.

Rob Bonta, Attorney General, Chris A. Knudsen, Assistant Attorney General, Alice Quinton and Rebecca M. O’Grady, Deputy Attorneys General, for Defendant and Appellant.

Middlebrook & Associates, Richard O. Middlebrook and Gabrielle Barnett, for Plaintiff and Respondent.

When a driver is lawfully arrested on suspicion of driving under the influence (DUI) and refuses to consent to chemical testing of their blood or breath pursuant to California’s implied consent law, the Department of Motor

Vehicles (DMV) may suspend the driver’s license for one year. (Veh. Code,1 § 13353, subd. (a)(1).) If the DMV proposes to impose such a suspension, the driver is entitled to an “administrative per se” (APS) hearing. (§ 13558, subd. (a); see generally Lake v. Reed (1997) 16 Cal.4th 448, 462.)

Four years ago in California DUI Lawyers Association v. Department of Motor Vehicles (2022) 77 Cal.App.5th 517 (DUI Lawyers), the plaintiff challenged the procedure by which the DMV conducted APS hearings, seeking both declaratory and injunctive relief by contending that the hearing officer’s dual role as advocate and adjudicator violated state and federal due process requirements. (Id. at p. 530; see Romane v. Department of Motor

Vehicles (2025) 110 Cal.App.5th 1002, 10142 (Romane) [“DUI Lawyers was a taxpayer action challenging the DMV’s policies and procedures in the abstract”].) The Court of Appeal agreed, holding that because the procedure permitted the hearing officer to both “advocat[e] on behalf of the DMV and

1 All statutory references are to the Vehicle Code unless otherwise indicated. 2 The Supreme Court granted review in Romane on August 13, 2025 (S291093). The court’s order limited review to the question “[u]nder what circumstances does an administrative per se hearing officer’s relationship with the Department of Motor Vehicles (DMV) violate a driver’s due process right to an impartial adjudicator by creating an unacceptable risk of bias during a DMV driver’s license suspension hearing?” (Romane, S291093, Supreme Ct. Mins., Aug. 13, 2025.) The order also provided that the Court of Appeal opinion remained citable “for its persuasive value” and “for the limited purpose of establishing the existence of a conflict in authority.” (Ibid.)

act[] as fact finder” (DUI Lawyers, at p. 532), it created an unacceptable risk of bias that was inconsistent with due process guarantees.

DUI Lawyers did not involve a license suspension, but in the years since it was decided other courts have been required to address whether and when the “ ‘ “unacceptable risk of bias” ’ ” created by the procedure requires invalidation of a suspension order applicable to a particular driver. (DUI Lawyers, supra, 77 Cal.App.5th at p. 532.) This is another in that line of cases, one of which was this court’s decision in Romane, where we upheld a license suspension after concluding on the particular facts of the case that the hearing officer did not act as an advocate for the DMV. (Romane, supra, 110 Cal.App.5th at pp. 1009, 1018–1019, review granted.)

Petitioner Amini candidly concedes that the facts of this case are indistinguishable from Romane. Pending guidance from the Supreme Court, we see no reason to depart from our reasoning in that case. Accordingly, we reverse.

FACTUAL AND PROCEDURAL BACKGROUND

Amini was arrested on suspicion of DUI in September 2023. He refused the arresting officer’s request to voluntarily provide a blood or breath sample. Ultimately a warrant was issued and Amini was subject to a forcible blood draw.

A. The APS Hearing

Amini’s APS hearing was conducted in January 2024 before a DMV hearing officer. At the beginning of the hearing, the hearing officer announced that he would be “acting as a neutral fact finder and [was] prohibited from and will not act as an advocate for the DMV or law enforcement.” His role was “to review the evidence provided, ask any

clarifying questions if necessary, and make legal rulings and determinations under the relevant statutes.” He then identified six documents he would consider “on behalf of this Department,” including a DS-367 form, a traffic collision report, an arrest report, a police incident report, a body worn camera (BWC) recording, and Amini’s current driving record.

Amini’s counsel objected, claiming that the APS hearing procedure violated the holding in DUI Lawyers. In his view, when the hearing officer “presented evidence on behalf of the [DMV]” to further the goal of denying Amini his driving privileges, he was acting as both an advocate for the DMV and as an adjudicator, which violated Amini’s due process rights.

The hearing officer saw the matter differently. He first rejected Amini’s objection to the overall procedure, believing that he was not advocating for the DMV. Merely identifying the six pieces of seemingly relevant evidence did not mean he would substantively consider them. Rather, he indicated he would decide whether to consider them, and he offered Amini’s counsel the opportunity to explain “why it shouldn’t be considered.” Counsel offered no specific objection to any of the documents, but he reiterated his general objection that the hearing officer was advocating for the DMV. “[I]f you are not their advocate,” counsel argued, “then there is no proper person or entity that is submitting [the evidence] for consideration.” Noting that he understood Amini’s position, the hearing officer nonetheless admitted the six documents into evidence. At that point, Amini’s counsel indicated, “I have nothing further,” and the matter was taken under submission. Less than a month later, the hearing officer issued a written ruling upholding the suspension of Amini’s license.

B. The Writ Proceeding in the Superior Court

Amini filed a petition for writ of mandate in the superior court to challenge the hearing officer’s decision. As he argued at the APS hearing, Amini maintained his due process rights were violated because the hearing officer acted as both an advocate for the DMV and the decision maker, contrary to the holding in DUI Lawyers.

The superior court agreed with Amini, directing the DMV to vacate its decision and conduct a new hearing with separate individuals serving as the advocate and the hearing officer. Relying on the then-recent decision in Knudsen v. Department of Motor Vehicles (2024) 101 Cal.App.5th 186, the DMV had argued that the court should examine the specific behavior of the hearing officer to determine whether he “actually acted as both an adjudicator and an advocate, or merely acted as an adjudicator and a collector and developer of evidence.” (Id. at p. 193.) But the superior court rejected this approach, terming it “problematic and unworkable.”

The court’s ruling in the form of a minute order was filed on June 17, 2024. A judgment granting a writ of mandate was ultimately entered on January 9, 2025, from which the DMV now appeals.

DISCUSSION

A. Timeliness of the Appeal

Before we consider the due process issue that lies at the heart of this appeal, we must first address a preliminary procedural argument raised by Amini. He contends the DMV’s appeal is untimely and must be dismissed.

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