Everett v. Mountains Recreation & Conservancy Auth.

Plaintiff filed a putative class action suit against MCRA, alleging that the stop sign violation for which MRCA cited him occurred on a “highway” as defined by Vehicle Code section 360, that Vehicle Code section 21 makes the provision of the Vehicle Code uniformly applicable to all “highways” located in California, that Vehicle Code section 21455.5 governs automated traffic enforcement systems, and that MRCA failed to comply with the requirements of Vehicle Code section 21455.5 in establishing its automated video camera traffic enforcement system. At issue on appeal is whether MCRA is unlawfully imposing administrative penalties - in substantive effect fines for moving traffic violations - on motor vehicle owners. The court concluded that the trial court correctly ruled that it is “immaterial” whether or not the roadway in MRCA-controlled parkland where plaintiff was administratively cited is a “highway” as defined in Vehicle Code section 360. Highway or not in plaintiff's case, the court found that the MRCA Ordinance does not conflict with Vehicle Code section 21’s general prohibition against local vehicle ordinances in favor of uniform state vehicle laws. Because the court held that MRCA’s automated video camera traffic enforcement system is not subject to the Vehicle Code’s provisions governing automated traffic enforcement systems, the trial court correctly sustained MRCA’s demurrer. View "Everett v. Mountains Recreation & Conservancy Auth." on Justia Law