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Fahy v. Commissioner
No. 05-CV-97-M (D.N.H. filed March 23, 2005) ; Clearinghouse Number: 55917
Description
Legal Noncitizen New Hampshire Residents File Section 1983 Suit Against Division of Motor Vehicles for Discriminatory Licensing Rules
Abstract
In a suit brought under Section 1983, plaintiff legal noncitizen
New Hampshire residents alleged that New Hampshire Division of
Motor Vehicles Department of Safety’s drivers’ license
rules and practices violated their equal protection rights,
constitutional right to travel, and due process rights. Plaintiffs
include permanent residents, refugees, and asylees. Division of
Motor Vehicles requires legal noncitizens to (1) apply for and
renew their licenses at the central division office; (2) show proof
of residency at each license application and renewal; (3) retake
road skills tests in more instances than citizens; and (4) renew
their licenses more frequently than citizens. Division of Motor
Vehicles issues forty-five-day temporary paper licenses to
noncitizens rather than photo identification. Seeking injunctive
relief against enforcement of the rules, plaintiffs argue that
money damages cannot remedy the deprivation of constitutional
rights, that plaintiffs are experiencing substantial hardship, and
that the rules were developed for reasons of administrative
convenience, which does not outweigh constitutional violations and
is not a compelling state interest. The rules were intended to
solve problems of delays at Division of Motor Vehicles’
substations; state officials believed that delays were caused by
noncitizens with limited English-speaking skills.
