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Justices answer venue question in lifetime license forfeiture relief case

December 5, 2018

Indiana Supreme Court justices on Wednesday ruled that trial courts have jurisdiction to grant specialized driving privileges as relief from driver’s license forfeitures imposed in other counties.

Daniel Reinhart received two driver’s license suspensions in 2012 and 2015 for habitual traffic violations that occurred in Adams County. He received a third suspension as a lifetime forfeiture after a 2015 felony conviction for driving while suspended as a habitual traffic violator in Noble County.

In 2017, Reinhart petitioned the Adams Superior Court for specialized driving privileges, seeking relief from all three suspensions under Indiana Code section 9-30-16-4. Reinhart was granted his petition, despite argument that the Adams Superior Court lacked jurisdiction to stay or modify the lifetime forfeiture imposed by the Noble Superior Court. The Indiana Court of Appeals reversed and remanded, instructing the trial court to “vacate that portion of its order related to Reinhart’s Noble County suspension.”

But the high court affirmed the trial court’s ruling in an attempt “to provide a path forward for those in Reinhart’s position.”

First, it found that the specialized driving privileges statute established venue requirements and that the Adams Superior Court did not lack subject matter jurisdiction to stay the lifetime license forfeiture imposed by the Noble Superior Court.

It then found that absent a conviction modification, a lifetime license forfeiture under Ind. Code § 9-30-10-16 (2014) would be an administrative suspension.

“We agree with the State that only trial courts may impose criminal judgments,” Judge Mark Massa wrote. “But the ‘required forfeiture of a defendant’s driver’s license [is] a collateral consequence of a guilty plea’ and conviction, ‘not [a] punishment imposed by the court.’”

“The State’s reading of the statute, by contrast, would require individuals to petition each court from which a lifetime forfeiture arose, increasing exponentially the number of SDP petitions filed and adding to the already-congested dockets of our trial courts,” Massa continued.

Justices further concluded that a conviction modification under Section 16 would result in a court-ordered suspension.

“This conclusion fits logically with Section 3’s venue requirement that a suspended driver seek relief from the court (or courts) that modified the suspended driver’s conviction. As Reinhart notes, the ‘duration of the suspension’ imposed by the court depends ‘on the facts of that particular case, including the nature and severity of the offense, as well as the character of the defendant.’”

“A nondiscretionary lifetime forfeiture, on the other hand, depends simply on the defendant’s HTV status, not the specific facts of the case or the agreed upon conditions he must fulfill to reduce the sentence,” Massa concluded.

The high court therefore affirmed the trial court’s order granting Reinhart’s petition for relief from all three suspensions under Indiana Code section 9-30-16-4 in State of Indiana and Indiana Bureau of Motor Vehicles v. Daniel Reinhart,18S-MI-286.

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