State v. Bell

572 N.W.2d 910, 1997 Iowa Sup. LEXIS 355, 1997 WL 800547
CourtSupreme Court of Iowa
DecidedDecember 24, 1997
Docket96-2254
StatusPublished
Cited by11 cases

This text of 572 N.W.2d 910 (State v. Bell) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bell, 572 N.W.2d 910, 1997 Iowa Sup. LEXIS 355, 1997 WL 800547 (iowa 1997).

Opinions

LARSON, Justice.

Walter Bell pled guilty to possession of marijuana in violation of Iowa Code section 124.401(3) (1995). As part of the sentence, the court ordered that Bell’s driver’s license be revoked as provided by 1996 Iowa Acts chapter 1218, section 68 (now codified at Iowa Code section 901.5(10) (1997)). Bell appealed on the grounds that the revocation order violated the Due Process and Equal Protection Clauses of the United States and Iowa Constitutions. U.S. Const, amends. V, XIV, § 1, Iowa Const, art. I, § 9 (due process); U.S. Const, amend. XIV, § 1, Iowa Const, art. I, § 6 (equal protection). We affirm.

Because Bell raises constitutional claims, we review the case de novo. Bruns v. State, 503 N.W.2d 607, 609 (Iowa 1993). Because of their similarity, we will treat the issues under the federal and state constitutional provisions simultaneously. Bell concedes that his driving privilege does not rise to the level of a fundamental right and that the statute does not create a suspect classification; therefore, his constitutional claims are examined under a rational-basis analysis. Glowacki v. State Bd. of Med. Exam’rs, 501 N.W.2d 539, 541 (Iowa 1993). Under this analysis, a statute is constitutional “unless it is patently arbitrary and bears no rational relationship to a legitimate governmental interest.” Id. Under the rational-basis test, (1) the statute must serve a legitimate governmental interest, and (2) the means employed by the statute must bear a rational relationship to that interest. Id.

The statute in question, Iowa Code § 901.5(10) (1997), provides:

In addition to any sentence imposed pursuant to chapter 902 [felonies] or 903 [misdemeanors], the court shall order the state department of transportation to revoke the defendant’s driver’s license or motor vehicle operating privilege for a period of one hundred eighty days ... if the defendant is being sentenced for any of the following offenses:
a. A controlled substance offense under section 124.401_

Statutes are presumed to be constitutional, and the challenger carries a heavy burden of rebutting this presumption. Glowacki, 501 N.W.2d at 541. We are reluctant to interfere with the legislature’s latitude in fixing punishment, and to be found unconstitutional, a statute “must clearly, palpably, and without doubt infringe upon the constitution.” Id. (citations omitted). The prevailing view is that statutes similar to the one in this case are valid under the rational-basis test for due process and equal protection. See generally Jeffrey T. Walter, Annotation, Validity and Application of Statute or Regulation Authorizing Revocation or Suspension of Driver’s License for Reason Unrelated to Use of, or Ability to Operate, Motor Vehicle, 18 A.L.R.5th 542, 551 (1994 & Supp. 1997).

I. The Due Process Claim.

Bell argues that the revocation requirement is an extreme response to a minor offense such as possession of marijuana. He [912]*912contends that the revocation of driving privileges bears no significant relationship to the legislative objective of public safety on the highway. However, under the rational-basis test, it is not enough for a party challenging the statute to show that the connection between the governmental purpose and the means used is “insignificant.” The challenger must show that the statute bears no rational relationship to the government’s interest. Glowacki, 501 N.W.2d at 541.

A number of courts in other jurisdictions have held that similar statutes are valid under the rational-basis test. See, e.g., People v. Zinn, 843 P.2d 1351, 1354 (Colo.1993) (revocation sanction reasonable in view of governmental objective to prevent possession, use, or sale of controlled substances); Lite v. State, 617 So.2d 1058, 1060 (Fla.1993) (penalty rationally related to deterrence goal); Quiller v. Bowman, 262 Ga. 769, 425 S.E.2d 641, 642-43 (1993) (license suspension furthers state’s goal of deterring illegal drug use and transportation of illegal drugs); Mitchell v. State, 659 N.E.2d 112, 116 (Ind. 1995) (statute bears rational relationship to legitimate state interest in punishing and deterring lawbreaking).

We conclude, as have these and other courts, that punishment in the form of a license revocation is rationally related to the goals of the legislature in punishing and deterring the commission of crime.

II. The Equal Protection Claim.

Bell contends that this statute singles out drug offenders from other criminal defendants without a rational basis for doing so. He claims that the limitation to drug offenders is arbitrary because the mandatory revocation provision could also effectively deter crimes such as theft, burglary, and rape. He also points out that the statute imposes “the same penalty upon casual users of marijuana and repeat dealers of crack cocaine,” thereby suggesting that the statute is overbroad.

We have held that all persons need not be treated alike to meet constitutional standards for equal protection. Hack v. Auger, 228 N.W.2d 42, 43 (Iowa 1975). Moreover, the legislature has wide discretion in defining the limits of classes when a statute involves classifications of persons or things. If a classification is a reasonable one and operates equally , upon all within the class, it is a valid classification. State v. Hall, 227 N.W.2d 192, 194 (Iowa 1975).

We have stated the test for equal protection as follows:

“[T]he classification must be sustained unless it is patently arbitrary and bears no rational relationship to a legitimate governmental interest. It does not deny equal protection simply because in practice it results in some inequality; practical problems of government permit rough accommodations; and the classification will be upheld if any state of facts reasonably can be conceived to justify it.”

Id. (quoting Lunday v. Vogelmann, 213 N.W.2d 904, 907 (Iowa 1973) (citations omitted)).

There are a number of possible state interests that the statute advances. The legislature may have concluded that individuals convicted of drug offenses are more likely to cause dangerous conditions on public roads than are other criminal defendants because their drug use actually may impair their driving abilities. Moreover, the legislature may have believed that the statute would cut down on the transportation and trafficking of drugs and, therefore, the use of drugs, while it may not have believed that a similar revocation statute for more violent crimes would have reduced the incidence of such crimes. Any of these reasons would be sufficient to show that the statute is not patently arbitrary and therefore does not violate the Equal Protection Clause.

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Bluebook (online)
572 N.W.2d 910, 1997 Iowa Sup. LEXIS 355, 1997 WL 800547, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bell-iowa-1997.