City of Chesapeake v. Evans

91 Va. Cir. 247, 2015 Va. Cir. LEXIS 244
CourtChesapeake County Circuit Court
DecidedSeptember 29, 2015
DocketCase No. CL15-1440
StatusPublished

This text of 91 Va. Cir. 247 (City of Chesapeake v. Evans) is published on Counsel Stack Legal Research, covering Chesapeake County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Chesapeake v. Evans, 91 Va. Cir. 247, 2015 Va. Cir. LEXIS 244 (Va. Super. Ct. 2015).

Opinion

By Judge Randall D. Smith

This matter is before the Court pursuant to Va. Code § 16.1-131.1, regarding the ruling of the Chesapeake General District Court that Va. Code § 46.2-1054 (incorporated into the Chesapeake Code of Ordinances by Chesapeake Code § 74-4) is unconstitutionally vague. Both parties have filed written briefs, and the Court heard oral arguments of counsel on September 9, 2015. For the reasons that follow, the Court finds that the statute in question is not constitutionally infirm.

As provided by Va. Code § 16.1-131.1 and as conceded by counsel at the hearing on September 9, 2015, this Court’s jurisdiction in the instant case is limited to determining the constitutionality of Va. Code § 46.2-1054; therefore, the Court will not address the motion to suppress ruled upon by the General District Court and briefed by counsel.

Va. Code § 46.2-1054 provides:

It shall be unlawful for any person to drive a motor vehicle on a highway in the Commonwealth with any object or objects, other than a rear view mirror, sun visor, or other equipment of the motor vehicle approved by the Superintendent, suspended from any part of the motor vehicle in such a manner as to [248]*248obstruct the driver’s clear view of the highway through the windshield, the front side windows, or the rear window, or to alter a passenger-carrying vehicle in such a manner as to obstruct the driver’s view through the windshield. However, this section shall not apply (i) when the driver’s clear view of the highway through the rear window is obstructed if such motor vehicle is equipped with a mirror on each side, so located as to reflect to the driver a view of the highway for at least 200 feet to the rear of such vehicle, (ii) to safety devices installed on the windshields of vehicles owned by private waste haulers or local governments and used to transport solid waste, or (iii) to bicycle racks installed on the front of any bus operated by any city, county, transit authority, or transit or transportation district.

The arguments of the defendant and the opinion of the General District Court address an important topic of concern in the forum of public policy: how restrained police should be in their contact with members of the community in the detection of crime. However, we must be mindful of the separation of powers; under both the United States and Virginia Constitutions, each branch of government must respect the other branches. See Va. Const., art. Ill; see also U.S. Const., arts. I, II, and III; Va. Const., arts. IV, V, and VI. See generally The Federalist, Nos. 47 and 48 (James Madison). The judicial branch is often the branch charged with enforcing individual rights under the Constitutions. Our system of government envisions this as necessary because the rights of individuals may not adequately be protected or addressed by the other two branches. Nevertheless, the judicial branch should not usurp its position relative to the balance of a tripartite government in an effort to address all-important issues confronting the criminal justice system.

For example, our legislature considered the intrusion on citizens by police in passing a law making seatbelt violations a secondary offense to prevent police from using such violation as authority to stop a vehicle to investigate the possibility of a criminal offense. See Va. Code § 46.2-1094(F). The executive branch, from the Secretary of Public Safety down to local police chiefs and sheriffs, may also choose to limit by policy the manner of law enforcement contact with the public. Police conduct does not necessarily need to be established at constitutional limits. See Atwater v. City of Lago Vista, 532 U.S. 318, 354 (2001) (holding that the standard of probable cause “applies to all arrests, without the need to ‘balance’ the interests and circumstances involved in particular situations”; thus, an officer may, without violating the Fourth Amendment, arrest an offender if probable cause exists to believe that an individual has committed even a very minor criminal offense in his presence). The test of constitutionality, as applied by courts in cases before them cannot be synonymous with [249]*249each judge’s view of what constitutes “fair” police conduct, lest the line of conduct below which the police violate a defendant’s rights vary on too wide a spectrum.

In reviewing the constitutionality of a statute, a court’s “determination of legislative intent is guided by the recognition that all actions of the General Assembly are presumed to be constitutional.” Elizabeth River Crossings OpCo v. Meeks, 286 Va. 286, 301, 749 S.E.2d 176, 183 (2013) (quoting Montgomery Cnty. v. Virginia Dep’t of Rail & Pub. Transp., 282 Va. 422, 435, 719 S.E.2d 294, 300 (2011)). “There is ... no stronger presumption known to the law.” Id. Courts have a “duty to construe statutes subject to a constitutional challenge in a manner that ‘avoid[s] any conflict with the Constitution’.” Copeland v. Todd, 282 Va. 183, 193, 715 S.E.2d 11, 16 (2011) (quoting Commonwealth v. Doe, 278 Va. 223, 229, 682 S.E.2d 906, 908 (2009)); see Skilling v. United States, 561 U.S. 358, 406 (2010) (“The elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality.”) (emphasis in original). Courts “must resolve any reasonable doubt regarding the constitutionality of a law in favor of its validity.” Boyd v. County of Henrico, 42 Va. App. 495, 507, 592 S.E.2d 768, 774 (2004). “Accordingly, ‘only where the statute in issue is ‘plainly repugnant’ to a constitutional provision [should a court] declare it null and void’.” Elizabeth River Crossings, 286 Va. at 301, 749 S.E.2d at 183 (quoting Jamerson v. Womack, 244 Va. 506, 510, 423 S.E.2d 180, 183 (1992)); accord In re Phillips, 265 Va. 81, 85, 574 S.E.2d 270, 272 (2003). If a statute or ordinance “can be made constitutionally definite by a reasonable construction, the court is under a duty to give it that construction.” Pedersen v. Richmond, 219 Va. 1061, 1065, 245 S.E.2d 95, 98 (1979); accord Commonwealth v. Carter, 21 Va. App. 150, 153, 462 S.E.2d 582, 584 (1995).

“The constitutional prohibition against vagueness derives from the requirement of fair notice embodied in the Due Process Clause.” Tanner v. City of Virginia Beach, 277 Va. 432, 439, 674 S.E.2d 848, 852 (2009). The Fifth Amendment to the United States Constitution provides that “[n]o person shall... be deprived of life, liberty, or property, without due process of law”; further, Section 1 of the Fourteenth Amendment also provides that “[n]o state shall... deprive any person of life, liberty, or property, without due process of law.” This protection is echoed by Article I, Section 11, of the Constitution of Virginia. The Supreme Court of the United States has recognized that a government “violates this guarantee by taking away someone’s life, liberty, or property under a criminal law so vague that it fails to give ordinary people fair notice of the conduct it punishes, or so standardless that it invites arbitrary enforcement.” Johnson v. United States, _ U.S. _, 135 S. Ct. 2551, 2556 (2015); accord Skilling, 561 U.S.

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Cite This Page — Counsel Stack

Bluebook (online)
91 Va. Cir. 247, 2015 Va. Cir. LEXIS 244, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-chesapeake-v-evans-vaccchesapeake-2015.