Kittredge v. State

CourtVermont Superior Court
DecidedAugust 3, 2020
Docket565-10-19 Wncv
StatusPublished

This text of Kittredge v. State (Kittredge v. State) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kittredge v. State, (Vt. Ct. App. 2020).

Opinion

Kittredge v. State, No. 565-10-19 Wncv (Tomasi, J., Aug. 3, 2020).

[The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

STATE OF VERMONT SUPERIOR COURT CIVIL DIVISION Washington Unit Docket No. 565-10-19 Wncv

Lauren Kittredge, Plaintiff

v.

State of Vermont, Defendant

Opinion and Order on Appeal From the Department of Motor Vehicles

Petitioner Lauren Kittredge seeks review of the Vermont Department of

Motor Vehicles’ (DMV’s) decision, following a hearing, to suspend her right to

operate a motor vehicle. Vt. R. Civ. P. 74. Initially, DMV suspended her license for

15 days and, then, indefinitely. Ms. Kittridge requested a hearing concerning the

suspension. After a hearing before an administrative hearing examiner, the officer

affirmed the suspension concluding that the evidence supported the determination

that Ms. Kittredge was “incompetent” to drive and that her past conduct showed

that her continued operation posed a threat to the general public. 23 V.S.A. §

671(a). The Commissioner of DMV approved the examiner’s ruling. Ms. Kittredge

appealed that determination to this Court.

I. Standard

Ms. Kittredge’s appeal is on the record pursuant to Rule 74. See 23 V.S.A. §

105(b) (“A person aggrieved . . . may have such decision reviewed by the Superior

1 Court pursuant to Rule 74 of the Vermont Rules of Civil Procedure.”). The Vermont

Supreme Court has described the nature of Rule 74 review as follows:

Courts presume that the actions of administrative agencies are correct, valid and reasonable, absent a clear and convincing showing to the contrary. Therefore, judicial review of agency findings is ordinarily limited to whether, on the record developed before the agency, there is any reasonable basis for the finding. Courts must remember that “(a)dministrative agencies belong to a different branch of government,” and that “(t)hey are separately created and exercise executive power in administering legislative authority selectively delegated to them by statute.”

State Dep’t of Taxes v. Tri-State Indus. Laundries, Inc., 138 Vt. 292, 294 (1980)

(citations omitted).

II. Analysis

The legal framework for suspending a driver’s license is found in 23 V.S.A. §

671(a). It provides:

In his or her discretion, the Commissioner may suspend indefinitely or for a definite time the license of an operator, or the right of an unlicensed person to operate a motor vehicle, after opportunity for a hearing upon not less than 15 days' notice, if the Commissioner has reason to believe that the holder thereof is a person who is incompetent to operate a motor vehicle or is operating improperly so as to endanger the public.

Id.1

The hearing examiner in this proceeding concluded that Ms. Kittredge’s

license to operate should be suspended on both of the grounds listed above: he found

1 Similarly, the Commissioner may refuse “to issue a license to any person whenever he or she is satisfied from information given him or her by credible persons, and upon investigation, that the person is mentally or physically unfit, or because of his or her habits, or record as to accidents or convictions, is unsafe to be trusted with the operation of motor vehicles.” 23 V.S.A. § 603.

2 that she was both “incompetent to operate a motor vehicle” and had history of

“improperly operating so as to endanger the public.” Id. Those determinations

were based on the examiner’s determination that Ms. Kittredge had been charged

with multiple instances of driving under the influence of alcohol but had not been

convicted because she had been found “incompetent” to stand trial. In making those

determinations, the examiner relied upon a letter submitted by the Washington

County State’s Attorney, a court document detailing Ms. Kittredge’s criminal

history, and the Information and sworn affidavits prepared by law enforcement in

connection with the Washington County charges. There is no dispute that the

Washington County charges were dismissed at the time of the hearing and that

earlier charges from Rutland County remained pending.

On appeal, Ms. Kittredge maintains that it was improper for the examiner to

rely on hearsay documents to make his ruling. She contends that such evidence is

not of a type reasonably relied upon by persons in the context of their daily affairs.

23 V.S.A. § 810. She also asserts that admitting such evidence denied her due

process because she was unable to “cross-examine” the drafters of the documents.

Additionally, she argues that the Commissioner erred in relying on evidence of

pending criminal cases in violation of 23 V.S.A. § 671(c) & (d). As to incompetency,

she submits that the medical reports admitted below rebut any claim of

incompetence. Lastly, she maintains that the Commissioner was required to order

an examination of her, pursuant to 23 V.S.A. § 636, prior to seeking a suspension of

her license.

3 The Commissioner disagrees on all fronts. She asserts that the evidentiary

provisions of Section 810 do not apply to the proceedings involved in this case, that

Ms. Kittredge was provided due process, that it was appropriate to rely on pending

criminal matters under these circumstances, that the evidence submitted is

sufficiently reliable and convincing to support the Commissioner’s decision, and

that the provisions of Section 636 are discretionary and do not limit the ability of

the Commissioner to take affirmative action under Section 671 where warranted by

the evidence.

The Court makes the following determinations.

First, the Court disagrees with Ms. Kittredge’s contention that the

Commissioner is required to proceed initially under the examination procedures of

Section 636 anytime the Commissioner believes a driver is incompetent or poses a

danger to the travelling public. The plain language of Section 636 is discretionary

and optional. It indicates that the Commissioner “may” seek a “special

examination” of a questionable driver, and, “If” the Commissioner does, it describes

the types of examinations that may be required. Nothing in the language suggests

that it is mandatory and nothing in Section 671 demands that a suspension

determination must be made pursuant to an examination performed under Section

636.

The Court concludes that suspensions under Section 671 may proceed based

on evidence obtained by the Commissioner without first requiring an examination

under Section 636. That conclusion is supported by the language of the statute and

4 by the interpretation of the Commissioner who is charged with enforcement of the

law. See Agency of Nat. Res. v. Supeno, 2018 VT 30, ¶ 23, 207 Vt. 108, 116–17 (if

statute is ambiguous or silent, courts “will defer to agency interpretation of a

statute within its area of expertise as long as it represents a permissible

construction of the statute” (internal quotations omitted)).

Second, the Court agrees with the Commissioner that the Rules of Evidence

are not applicable in these proceedings. 3 V.S.A. § 816(b) makes clear that hearings

of the type involved in this action are not subject to the “contested case” evidentiary

provisions set out in 3 V.S.A. § 810. See 23 V.S.A. § 105(a) (describing hearings

before the Commissioner).

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Related

In Re Miller
2009 VT 112 (Supreme Court of Vermont, 2009)
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Kittredge v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kittredge-v-state-vtsuperct-2020.