Gutridge v. Virginia

532 F. Supp. 533, 1982 U.S. Dist. LEXIS 10483
CourtDistrict Court, E.D. Virginia
DecidedJanuary 28, 1982
DocketCiv. A. No. 81-0614-A
StatusPublished
Cited by2 cases

This text of 532 F. Supp. 533 (Gutridge v. Virginia) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gutridge v. Virginia, 532 F. Supp. 533, 1982 U.S. Dist. LEXIS 10483 (E.D. Va. 1982).

Opinion

MEMORANDUM OPINION

RICHARD L. WILLIAMS, District Judge.

Plaintiff Warnie H. Gutridge is a truck driver who operates vehicles both wholly in Virginia and in interstate commerce. Plaintiff Jay’s Trucking Co., Inc., is Gut-ridge’s employer. It owns trucks that travel in both intrastate and interstate commerce. Plaintiff Milton F. Wright Trucking Inc. also owns trucks that operate in both streams of commerce. The plaintiffs have filed a section 1983 action seeking a [535]*535declaratory judgment that Virginia’s system of truck weight regulations is unconstitutional. See 28 U.S.C. § 2201 (1976); 42 U.S.C. § 1983 (1976). They contend that these restrictions violate both the equal protection clause and the commerce clause. The plaintiffs also request an injunction prohibiting further enforcement of the challenged regulations. The defendant in this suit is the Commonwealth of Virginia.

I. FACTUAL BACKGROUND

Virginia’s state legislature has enacted a series of vehicle weight regulations. See Va. Code §§ 46.1-339 to -347 (1980). Section 46.1-339 provides a schedule of the maximum truck weights generally permitted on Virginia’s roads. See id. § 46.1-339(d). These weight limits vary with the number of axles that a truck has and the distance in feet between the first and last axles. See id. The limits range from 34,-000 pounds for a two-axle vehicle with a four-foot axle distance to 76,000 pounds for a five-axle truck with a forty-five-foot axle distance.1

The sections that follow section 46.1-339 create several exceptions to the general weight schedule. Four of these exceptions are relevant to the present case. First, section 46.1-343(a)(2) raises the weight limits for vehicles “carrying containerized cargo in a sealed, seagoing container bound to or from a Virginia seaport.” Id. § 46.1-343(a)(2). Trucks hauling such containers may have a gross weight of up to 78,000 pounds. See id.

The second exception is section 46.1-343(bl). This provision raises the weight ceilings for “three-axle vehicles used exclusively for the mixing of concrete in transit or at a project site or for transporting necessary components to produce concrete immediately upon arrival at the project site.” Id. § 46.1-343(bl). Trucks qualifying under this exception may have a gross weight. of up to 60,000 pounds. See id.

Third, section 46.1-343(c) increases the weight limit for special vehicles used in hauling coal from the mine to the preparation plant, loading dock, or railroad. See id. § 46.1-343(c). The maximum gross weights allowed under this provision are 60.000 pounds for three-axle vehicles and 70.000 pounds for four-axle vehicles. See id. To qualify for this exception, a truck [536]*536must be designed to permit a visual determination of whether it is carrying more than the permitted amount of coal.2 Furthermore, the vehicle may not operate at the higher weight limits for more than thirty-five miles from the preparation plant, loading dock, or railroad. See id.

The final exception that is relevant in this case is section 46.1-343.1. This provision raises the weight ceilings for trucks hauling farm produce on the Eastern Shore. See id. § 46.1-343.1. Three-axle vehicles may have a gross weight of up to 50,000 pounds. See id. The section does not change the maximum gross weight for four-axle trucks. It, however, does raise the maximum tandem axle weight for such vehicles to 36,000 pounds. See id.

On October 30, 1980, Warnie Gutridge was convicted in the Fairfax County Circuit Court on two counts of operating a truck in violation of section 46.1-339. Gutridge was assessed fines, costs, and liquidated damages totalling $2,900. He appealed these convictions to the Supreme Court of Virginia. The higher court, however, denied certiorari on May 1, 1981. Gutridge has not attempted to appeal his case to the United States Supreme Court.

Jay’s Trucking Co., Inc., and Milton F. Wright Trucking have applied for permits to operate their vehicles under the various weight exceptions contained in sections 46.-1-343 and 46.1-343.1. The authorities empowered to issue such permits, however, have continuously denied or deferred the two companies’ applications. Furthermore, the two trucking concerns clearly are not eligible for the permits under the language of the statutes. Their trucks, nonetheless, are capable of hauling the same bulk commodities that are carried by vehicles qualifying under the exceptions. These commodities include concrete, coal, and farm produce.

On June 23, 1981, Gutridge, Jay’s Trucking Co., and Milton F. Wright Trucking filed a section 1983 action against the Commonwealth of Virginia. In this suit, the plaintiffs allege that Virginia’s system of truck weight regulations is unconstitutional on two grounds. First, they contend that the presence in the system of containerized cargo, concrete-mixer, coal-hauling, and Eastern Shore produce exceptions violates the equal protection clause. Second, the plaintiffs argue that the weight system as a whole is invalid under the commerce clause. The defendant moves for summary judgment on these claims.

II. THE EQUAL PROTECTION ISSUE

The plaintiffs’ first claim is that sections 46.1- 343(a)(2), 46.1-343(bl), 46.1-343(c), and 46.1- 343.1 of the Virginia Code violate the equal protection clause. Each of these sections restricts its weight limit exception to a narrow class of vehicle operators. The plaintiffs are not eligible for any of these exceptions. They argue that these provisions unlawfully discriminate against them, because there is no rational basis for distinguishing between them and the members of the eligible classes.

The level of scrutiny to which the court must subject Virginia’s weight regulations depends on whether the regulations affect either a suspect class or a fundamental right. If the challenged state action does not involve either of the two, it will not “be subjected to the searching judicial scrutiny reserved for laws that create suspect classifications or impinge upon constitutionally protected rights.” San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 40, 93 S.Ct. 1278, 1300, 36 L.Ed.2d 16 (1973). It, instead, will receive “the traditional standard of review, which requires only that the State’s system be shown to bear some rational relationship to legitimate state purposes.” Id. Accord McGinnis v. Royster, 410 U.S. 263, 270, 93 S.Ct. 1055, 1059, 35 L.Ed.2d 282 (1973).

[537]*537Virginia’s system of weight restrictions clearly does not create a suspect classification. A suspect class is one which is “saddled with such disabilities, or subjected to such a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process.” San Antonio Independent School District v. Rodriguez, 411 U.S. at 28, 93 S.Ct. at 1293.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Moore
701 P.2d 684 (Supreme Court of Kansas, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
532 F. Supp. 533, 1982 U.S. Dist. LEXIS 10483, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gutridge-v-virginia-vaed-1982.