The Maryland Court of Special Appeals today affirmed summary judgment against the Plaintiffs in the case of Pulliam v. Motor Vehicle Administration, a tragic case involving the death of a man and his three children in a rear-end car accident at the intersection of Butterfly Lane and Jefferson Pike in Frederick County.
Facts of Pulliam
The battlefield in this appellate battle was whether Pulliam’s driver’s license had been properly suspended by the MVA. Pulliam claimed that the MVA had suspended his license without providing him with adequate notice or an opportunity to contest the suspension. The MVA, on the other hand, argued that Pulliam had been properly notified of the suspension and that he had been given a fair opportunity to contest it. For context, Pulliam was not having license issue for bad behavior – he was having seizures.
The case was heard in a Maryland Frederick Circuit Court, where both parties presented evidence and testimony to support their arguments. The court ultimately found in favor of Pulliam, ruling that the MVA had violated his due process rights by suspending his license without providing him with adequate notice or an opportunity to contest the suspension.
In its ruling affirming the trial court, the Maryland Court of Special Appeal emphasized the importance of providing individuals with proper notice and an opportunity to contest administrative actions, such as the suspension of a driver’s license, that can have significant consequences for their daily lives. The court also noted that due process requires that individuals be given a fair opportunity to challenge government actions that affect their rights and interests, and that this principle applies to the suspension of a driver’s license.
Meaning of Pulliam
The decision in Pulliam was significant in several ways. First, it underscored the importance of providing individuals with proper notice and an opportunity to contest administrative actions that can have significant consequences for their daily lives. This ruling also reinforced the principle that due process requires that individuals be given a fair opportunity to challenge government actions that affect their rights and interests, and that this principle applies to the suspension of a driver’s license.
In addition, the ruling was seen as a victory for individuals who have had their driver’s licenses suspended, as it reinforced the principle that the state must provide proper notice and an opportunity to contest such suspensions in order to comply with due process requirements. This ruling was also seen as a warning to government agencies, such as the MVA, to ensure that they follow proper procedures when taking administrative actions that can affect the rights and interests of individuals.
Despite the outcome of this case, it remains important for individuals to understand their rights and responsibilities when it comes to driver’s license suspension and other administrative actions. Individuals who have had their licenses suspended should seek legal advice as soon as possible to ensure that their due process rights have been respected and to protect their rights.
Take Home Message
Pulliam is a significant legal dispute in the area of driver’s license suspension and due process, emphasizing the importance of providing individuals with proper notice and an opportunity to contest administrative actions that can have significant consequences for their daily lives. The decision was seen as a victory for individuals who have had their driver’s licenses suspended, as it reinforced the principle that the state must provide proper notice and an opportunity to contest such suspensions in order to comply with due process requirements.
Faced with what I’m sure was a limited policy given the scope of the tragedy, the plaintiff’s accident lawyer did what good accident lawyers do: they got creative. (I don’t know whose case this is. If you handled it, let me know so I can give you credit.)
The plaintiffs’ lawyer brought suit against the Maryland MVA and its Medical Advisory Board (MAB). The MAB required the at-fault driver to submit affidavits that he was seizure-free every three months because he had caused a prior accident three years earlier because of a seizure. Even though the at-fault driver did not submit such an affidavit that he was seizure-free, his license was not revoked.
The court assumed for the sake of the appeal what clearly appears to be the case: the MVA should have revoked the at-fault driver’s license. But the court found that the MVA and the MAB had no duty to the people that were killed in this accident. Moreover, the Maryland Court of Special Appeals found that Maryland’s statutory scheme to empower the MVA to issue or revoke licenses for people with seizure disorders cannot be the basis for a negligence claim resulting from a car accident.
I largely agree with the Maryland Court of Special Appeals’ holding, but this case underscores that serious auto accident victims are rarely fully compensated because of the limitations of automobile insurance. The only way car accident victims can avoid unreasonable outcomes is to make sure they have high uninsured motorist coverage.