In re The Bright Ideas Co.

CourtDistrict of Columbia Court of Appeals
DecidedNovember 10, 2022
Docket19-CV-1032
StatusPublished

This text of In re The Bright Ideas Co. (In re The Bright Ideas Co.) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In re The Bright Ideas Co., (D.C. 2022).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 19-CV-1032

IN RE: THE BRIGHT IDEAS COMPANY, INC., APPELLANT.

Appeal from the Superior Court of the District of Columbia (CAT-5718-19)

(Hon. Anthony C. Epstein, Reviewing Judge)

(Argued October 26, 2021 Decided November 10, 2022)

John A. Galbreath for appellant.

Mary L. Wilson, Senior Assistant Attorney General at the time, with whom Karl A. Racine, Attorney General for the District of Columbia, Loren L. AliKhan, Solicitor General at the time, Caroline S. Van Zile, Principal Deputy Solicitor General at the time, and Carl J. Schifferle, Deputy Solicitor General, were on the brief, for appellee.

Before BECKWITH, EASTERLY, and DEAHL, Associate Judges.

DEAHL, Associate Judge: This appeal, while superficially about a $100

speeding ticket, raises far more important stakes about an institutional litigant’s

strategic attempts to evade this court’s review. After successfully defending a $100

speeding ticket through two layers of agency review and before the Superior Court,

the District of Columbia asked this court to summarily affirm and uphold the ticket. 2

When we denied that motion, and instead asked for supplemental briefing and

indicated we would hear oral argument in the matter—preliminary indications that

the challenge to the ticket may have some merit—the District “voided” the ticket,

tried to refund the already-paid fine, and now urges us to dismiss the appeal as moot.

We decline that invitation. Appellant, the Bright Ideas Company, has raised

constitutional and regulation-based challenges to how the District enforces its traffic

laws. The District’s decision to void its ticket at the twenty-fifth hour—in this rare

challenge to a speeding ticket that persists all the way to this court—has not rendered

those challenges moot. The voluntary cessation doctrine instructs that one party’s

“voluntary cessation of a challenged practice does not moot a case unless

‘subsequent events make it absolutely clear that the allegedly wrongful behavior

could not reasonably be expected to recur.’” Trinity Lutheran Church of Columbia,

Inc. v. Comer, 137 S. Ct. 2012, 2019 n.1 (2017) (quoting Friends of the Earth, Inc.

v. Laidlaw Env’t Servs. (TOC), Inc., 528 U.S. 167, 189 (2000)). We have no such

assurance here, as the District has given us no reason to think it has changed the

enforcement practices Bright Ideas now challenges. Rather, the District has made it

reasonably clear that it has not altered its challenged enforcement practices at all and

that its one-off act of voiding this ticket was done only to avoid a potential precedent-

setting loss. This court will not indulge such strategic attempts to evade review, 3

particularly where the District already took a bite at the apple when it unsuccessfully

sought summary affirmance.

On the merits, we agree with the Bright Ideas Company that the District

misapplied its traffic regulations in upholding the issued citation. When the District

cites a driver for violating a posted speed limit, as here, a viable defense is that the

posted speed limit sign is not “sufficiently legible to be seen by an ordinarily

observant person.” 18 D.C.M.R. § 2000.5. The District’s contrary view, that

whenever the posted limit is illegible, it may always resort to enforcing the so-called

default speed limit, see 18 D.C.M.R. § 2200.6, is not a reasonable interpretation of

the pertinent traffic regulations. We therefore reverse the agency’s order upholding

the citation.

I.

This case stems from a ticket issued after an automated traffic camera

photographed a car registered to Bright Ideas speeding on the 2900 block of Military

Road NW. Bright Ideas is a Maryland company whose sole proprietor was driving

the vehicle and would later represent his company as counsel throughout the legal

proceedings, including in this appeal. The ticket listed the car’s speed as 36 mph,

the “Posted Speed” as 25 mph, the infraction as “Speed 11-15” mph over the limit, 4

and the fine as $100. Bright Ideas challenged the ticket before a Department of

Motor Vehicles Adjudication Services Hearing Examiner, arguing that there was “no

clear signage of the speed limit” on that stretch of road, where the lone speed limit

sign was poorly positioned and partially obscured by tree branches. The hearing

examiner upheld the ticket, reasoning that “[i]n the District of Columbia, if you do

not know what the posted speed limit is, the law requires you to travel at 25 miles

per hour.” See 18 D.C.M.R. § 2200.6 (2019).

Bright Ideas appealed to the Department of Motor Vehicles’ Traffic

Adjudication Appeals Board, which also upheld the ticket. In its decision, the

Appeals Board considered two traffic regulations. First, it cited 18 D.C.M.R.

§ 2200.2 for the proposition that the 25 mph posted speed limit on this stretch of

Military Road was set by the Mayor and “determined to be safe and reasonable under

the conditions found to exist at the location.” Second, and in the alternative, it

looked to 18 D.C.M.R. § 2200.6, which at the time provided that “[o]n all streets

and highways, unless otherwise designated in accordance with [18 D.C.M.R.]

§ 2200.2, the maximum lawful speed shall be twenty-five miles per hour (25 mph).” 1

1 In June 2020, this regulation was amended to reduce the default speed limit to 20 mph. See 67 D.C. Reg. 7539 (June 12, 2020) (emergency rulemaking); 67 D.C. Reg. 11238 (Sept. 25, 2020) (final regulation). 5

Echoing the hearing examiner’s rationale, the unanimous three-member Appeals

Board reasoned that if Bright Ideas’ driver “did not observe a speed limit sign stating

otherwise, he should have observed the 25 mph [default] limit under the

regulations.”

Bright Ideas next petitioned the Superior Court for leave to challenge the

Appeals Board’s decision. See D.C. Code § 50-2304.05. In its petition, the company

asserted for the first time that the District was engaged in an unconstitutional practice

of “conduct[ing] speed camera surveillance and ticketing in locations where speed

limits are not reliably posted, and where drivers would not reasonably expect the

speed limit to be just 25 mph.” Bright Ideas contended that when drivers then

challenge the speed limit as improperly posted, the District “sidesteps the protests

by stating that it does not matter whether the speed limit is properly posted, because

any street in the District has a speed limit of just 25 mph if not posted” under 18

D.C.M.R. § 2200.6. The company argued that this scheme violated its due process

rights because, for speed limits, fair notice “means reliably posting those limits so

that drivers can regulate their behavior accordingly.”

The Superior Court denied Bright Ideas’ petition, finding that the “adequacy

of the signage” was “not legally relevant.” Citing the default speed limit, see 18 6

D.C.M.R. § 2200.6, it reasoned that if a speed limit sign “did not notify Bright Ideas

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