Brief Fact Summary. A clergyman in Georgia was involved in an accident when a child rode her bike into the side of his car. He challenged the constitutionality of the Georgia Motor Vehicle Safety Responsibility Act (Act), which prevented him from submitting evidence regarding his lack of fault prior to the suspension of his driver’s license.
Synopsis of Rule of Law. Once licenses are issued, they cannot be revoked without procedural due process required by the Fourteenth Amendment.
Thus, procedures adequate to determine a welfare claim may not suffice to try a felony charge.
View Full Point of LawIssue. Did the revocation of Petitioner’s license without affording him an opportunity to contest liability violate due process?
Held. Yes. Reversed. Once issued, licenses may become essential in the pursuit of a livelihood, as in the Petitioner’s case. Suspension of issued licenses involves state action that adjudicates important interests of licensees, and due process is required. The procedure set forth by the Act violated due process. Dissent. None. Concurrence. None.
Discussion. It is fundamental that, except for in emergency situations, States afford notice and opportunity for hearing appropriate to the nature of a case before terminating an interest. This case did not involve an emergency situation, and due process was violated.