Kai Nielsen v. Department Of Licensing

CourtCourt of Appeals of Washington
DecidedSeptember 30, 2013
Docket68133-8
StatusPublished

This text of Kai Nielsen v. Department Of Licensing (Kai Nielsen v. Department Of Licensing) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kai Nielsen v. Department Of Licensing, (Wash. Ct. App. 2013).

Opinion

o IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

KAI NIELSEN, DIVISION ONE en

Appellant, No. 68133-8-

v.

WASHINGTON STATE PUBLISHED OPINION DEPARTMENT OF LICENSING,

Respondent. FILED: September 30, 2013

Dwyer, J. — Washington's implied consent law provides for the revocation

of a licensee's driver's license where the licensee is arrested for driving while

under the influence and refuses to submit to a blood or breath alcohol test. The

law provides such licensees with procedural protections, including the right to

appeal to the superior court from an administrative license revocation. Following

license revocation, the licensee can apply for an ignition interlock driver's license

(IIDL), which allows the licensee to lawfully operate a motor vehicle during the

revocation. However, the IIDL statute precludes a licensee who obtains an IIDL

from thereafter asserting the statutory right to judicial appeal from the

administrative decision imposing the revocation. No. 68133-8-1/2

Kai Nielsen obtained an IIDL following the administrative revocation of his

driver's license pursuant to the implied consent law. He thereafter appealed from

the Department of Licensing's revocation ruling, seeking review of the ruling in

the superior court. The court dismissed Nielsen's appeal, determining that he

had waived his right to judicial review by obtaining an IIDL. Nielsen challenges

the superior court's decision, asserting that the appeal waiver provision is

unconstitutional. We conclude that the challenged provision, which is not

rationally related to a legitimate state interest, violates substantive due process

protections. Accordingly, we determine that the appeal waiver provision of the

IIDL statute is unconstitutional.

I

Washington's implied consent law was passed by popular initiative in

1968. Laws of 1969, ch. 1, § 1 (Initiative Measure No. 242, adopted Nov. 5,

1968); State v. Morales. 173 Wn.2d 560, 571-72, 269 P.3d 263 (2012). Codified

at RCW 46.20.308, the law "provides law enforcement officers with an effective

means of obtaining physical evidence of intoxication since any person operating

a motor vehicle on the roads of this state is deemed to have consented to the

administration of a blood alcohol test." State v. Bartels, 112 Wn.2d 882, 885, 774

P.2d 1183 (1989). "Ifthe driver refuses to take the test, the driver's license,

permit, or privilege to drive will be revoked or denied for at least one year." RCW

46.20.308(2)(a).

The people of Washington, in passing the implied consent initiative,

provided procedural protections to licensees who are subject to administrative

-2- No. 68133-8-1/3

license revocation pursuant to that law. See Laws of 1969, ch. 1, § 5.1 The statute provides to such licensees an administrative hearing before a Department

hearing officer to contest the license revocation. RCW 46.20.308(6)(b), .308(8).

Moreover, where the license revocation is sustained by the Department hearing

officer, the implied consent law grants to the licensee the right to access the

courts in order to challenge the administrative revocation:

If the suspension, revocation, or denial is sustained after such a hearing, the person whose license, privilege, or permit is suspended, revoked, or denied has the right to file a petition in the superior court of the county of arrest to review the final order of revocation by the department in the same manner as an appeal from a decision of a court of limited jurisdiction.

RCW 46.20.308(9). The license revocation may not be stayed during the

pendency of the appeal unless the court determines that the licensee "is likelyto

prevail in the appeal" and that he or she "will suffer irreparable injury" without a

stay.2 RCW 46.20.308(9). In 2008, our legislature enacted legislation providing for the issuance of an

IIDL to licensees whose regular driver's licenses had been revoked pursuant to

1As enacted in 1969, the law provided: If the revocation or determination that there should be a denial of issuance is sustained after [an administrative] hearing, the person whose license, privilege or permit is so affected shall have the right to file a petition in the superior court of the county wherein he resides, or, if a nonresident of this state, where the charge arose, to review the final order of revocation or denial by the department in the manner provided in RCW 46.20.334. Laws of 1969, ch. 1, §5. 2This exacting standard for obtaining a stay during the pendency of an appeal from an administrative revocation decision was not included in the initiative passed by the people of Washington in 1968. Rather, our legislature added this language by amendment of RCW 46.20.308 in 1995. See Laws of 1995, ch. 332, § 1. No. 68133-8-1/4

the implied consent law. RCW 46.20.385(1 )(a).3 An IIDL is a permit issued by the Department "that allows the person to operate a noncommercial motor

vehicle with an ignition interlock device while the person's regular driver's license

is suspended, revoked, or denied." RCW 46.04.217. The licensee may apply for

an IIDL at any time, including upon receiving notice of the revocation. RCW

46.20.385(1 )(b). However, pursuant to RCW 46.20.385(1 )(b), a person who

receives an IIDL is thereafter not entitled to the procedural protections provided

by the implied consent law: "A person receiving an ignition interlock driver's

license waives his or her right to a hearing or appeal under RCW 46.20.308."

Legislative bill reports demonstrate the concern prompting our legislature

to enact the IIDL statute. According to testimony before the legislature, a large

number of people whose licenses had been revoked were nevertheless

continuing to drive. H.B. Rep. on Second Substitute H.B. 3254, 60th Leg., Reg.

Sess. (Wash. 2008). The ignition interlock device was described as "[technology

[that] will prevent people from driving drunk," and, thus, issuance of an IIDL was intended to "hold [drunk drivers] accountable." H.B. Rep. on Second Substitute

H.B. 3254. Moreover, a legislative report noted that Department data showed a

"'significant difference in the amount of recidivism'" between those drunk drivers

who later had the ignition interlock device installed and those who did not. S.B.

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