Indiana Bureau of Motor Vehicles v. Prescott D. Craig

CourtIndiana Court of Appeals
DecidedSeptember 24, 2024
Docket24A-MI-00227
StatusPublished

This text of Indiana Bureau of Motor Vehicles v. Prescott D. Craig (Indiana Bureau of Motor Vehicles v. Prescott D. Craig) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Indiana Bureau of Motor Vehicles v. Prescott D. Craig, (Ind. Ct. App. 2024).

Opinion

IN THE

Court of Appeals of Indiana Indiana Bureau of Motor Vehicles and Attorney General of Indiana, Appellants-Respondents FILED v. Sep 24 2024, 8:50 am

CLERK Prescott D. Craig, Indiana Supreme Court Court of Appeals and Tax Court

Appellee-Petitioner

September 24, 2024 Court of Appeals Case No. 24A-MI-227 Appeal from the Morgan Superior Court The Honorable Brian H. Williams, Judge Trial Court Cause No. 55D02-2311-MI-1936

Opinion by Judge Tavitas Judges Crone and Bradford concur.

Court of Appeals of Indiana | Opinion 24A-MI-227 | September 24, 2024 Page 1 of 16 Tavitas, Judge.

Case Summary1 [1] Prescott Craig is an Indiana resident whose Indiana driving privileges have

been suspended. Separately, Craig’s driving privileges in Illinois have been

revoked. Because Craig’s Indiana driving privileges were suspended, Craig

petitioned the trial court for specialized driving privileges in Indiana, which the

trial court granted. The trial court ordered Craig to carry a “valid license or

permit” in his vehicle while exercising his specialized driving privileges.

Appellant’s App. Vol. II p. 20.

[2] Craig then requested that the Indiana Bureau of Motor Vehicles (“BMV”) issue

him a specialized driving privileges credential; however, the BMV refused to

issue the credential based on its interpretation of the interstate Driver License

Compact, Indiana Code Section 9-28-1-3. According to the BMV, because the

state of Illinois revoked Craig’s driving privileges in Illinois, the BMV cannot

issue Craig the credential. After exhausting his administrative remedies, Craig

then petitioned for judicial review, which the trial court granted. The trial court

ordered the BMV to issue Craig a specialized driving privileges credential. The

BMV and the Indiana Attorney General (collectively “Defendants”) now

appeal. Concluding that the Driver License Compact does not prohibit the

BMV from issuing Craig a specialized driving privileges credential, we affirm.

1 We held oral argument in this case on August 29, 2024. We thank counsel for their advocacy.

Court of Appeals of Indiana | Opinion 24A-MI-227 | September 24, 2024 Page 2 of 16 Issue [3] Defendants present one issue on appeal, which we restate as whether the trial

court erred by granting Craig’s petition for judicial review and ordering the

BMV to issue Craig a specialized driving privileges credential when, according

to the BMV, the BMV is precluded from issuing the credential under the Driver

License Compact.

Facts [4] Craig is an Indiana resident with an extensive history of traffic violations. His

Indiana driver’s license has been suspended numerous times due to Craig

driving while under the influence, driving while suspended, failing to file proof

of insurance, and other reasons. In 2010, Craig operated a vehicle while under

the influence in Illinois. As a result, that year, the BMV suspended Craig’s

Indiana driver’s license for three months. Additionally, because Craig had

accumulated three previous similar offenses, the state of Illinois, in 2012,

created a record indicating that Craig’s “Illinois driver’s license and/or

privileges” were revoked. Appellant’s App. Vol. II p. 36. Craig, however, had

never been a resident of Illinois nor held an Illinois driver’s license credential.

[5] Craig’s Indiana driving privileges were later suspended for unrelated reasons,

and, in July 2023, Craig petitioned the trial court for specialized driving

Court of Appeals of Indiana | Opinion 24A-MI-227 | September 24, 2024 Page 3 of 16 privileges to travel to and from his place of employment and other locations.2

Craig served his petition on the BMV and the Morgan County Prosecuting

Attorney in accordance with the governing statutory procedures. Neither the

prosecuting attorney nor the BMV objected to Craig’s request for specialized

driving privileges. On August 18, 2023, the trial court entered an order granting

Craig specialized driving privileges. The order required Craig to “carry on

his/her person, a valid license or permit issued by the Indiana Bureau of Motor

Vehicles or have the valid license or permit in the vehicle being operated by

[Craig].” Id. at 20.

[6] After the trial court granted Craig specialized driving privileges, Craig requested

that the BMV issue him a “driving credential that shows specialized driving

privileges . . . .” Tr. Vol. II p. 11. The BMV, however, refused to issue the

credential due to the state of Illinois’ revocation of Craig’s Illinois driver’s

license and/or privileges. The BMV instructed Craig to “clear the revocation . .

. in Illinois in order to be eligible for an Indiana driving credential.” Id. at 18.

Upon Craig’s subsequent request for an administrative review of the BMV’s

decision, the BMV conducted a material error review and found no material

error in its decision.

2 Craig’s petition noted the following Indiana driving privilege suspensions:

On or about July 22, 2015, for Operating While Intoxicated under Cause No. 55D01-1507-F6- 000110 (ID #30), for life; on or about May 23, 2019, for 10-Year Habitual (ID #45), with an expiration date of May 20, 2019; and on or about February 24, 20[1]9, for 10-Year Habitual (ID #42), with an expiration date of February 21, 2029. Appellant’s App. Vol. II p. 19.

Court of Appeals of Indiana | Opinion 24A-MI-227 | September 24, 2024 Page 4 of 16 [7] On November 2, 2023, Craig petitioned for judicial review of the BMV’s

decision. Defendants filed a response arguing that, pursuant to the Driver

License Compact, the BMV could not issue Craig a “driving credential until the

Illinois revocation is cleared.” Id. at 42. The trial court held a hearing on

Craig’s petition on December 15, 2023. Craig testified that he has only ever

been a resident of Indiana and has never held an Illinois driver’s license. Craig

argued that, because he has never held an Illinois driver’s license, the Illinois

revocation did not prohibit the Indiana BMV from issuing him the credential.

Defendants argued in response that, when an individual commits a traffic

offense in Illinois, that state’s procedure is to “create . . . a driver license record

for that individual and treat[] them as if they were licensed,” and, “in the

BMV’s eyes[,] that prohibits [the BMV] from issuing a driving credential to

[Craig],” pursuant to the Driver License Compact. Tr. Vol. II pp. 11, 14.

[8] Later that day, the trial court issued an order granting Craig’s petition for

judicial review. The trial court rejected Defendants’ interpretation of the Driver

License Compact that Illinois could “create a driver’s license[] for an Indiana

resident who has not requested an Illinois [d]river’s license[], by virtue of the

Indiana [r]esident driving through the state of Illinois” and that Illinois could

then “revoke[] the [d]river’s license[] they created but the Indiana [r]esident did

not request.” Appellant’s App. Vol. II p. 10. The trial court ordered the BMV

to issue Craig a “[d]river’s license/credential” reflecting his specialized driving

privileges. Id. at 12. Defendants now appeal.

Court of Appeals of Indiana | Opinion 24A-MI-227 | September 24, 2024 Page 5 of 16 Discussion and Decision [9] Defendants concede that Craig is permitted to drive in Indiana pursuant to the

terms of his specialized driving privileges. Defendants, however, argue that,

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