Seventh Circuit Review


With over one million fatalities occurring every year on the world's roadways, the safety of motorists, passengers, and pedestrians is a major public policy concern. In an effort to address this policy concern and prevent roadway fatalities and accidents, communities across the county have implemented automated enforcement technology systems, such as red light cameras. Proponents of red light camera legislation believe the laws are constitutional and effective, but critics claim that such laws fail to pass the rational-basis test required of all legislation. In Idris v. City of Chicago, the Court of Appeals for the Seventh Circuit considered whether a red light camera ordinance meets the requirements of the rational-basis test under both equal protection and due process. In a very brief analysis, the Seventh Circuit correctly held that the red light camera ordinance passes the rational-basis test; however, this Note argues that the court's application of the test was insufficient. Further, this Note expands upon the Seventh Circuit's reasoning by considering additional arguments raised by red light camera critics and discusses the implications of the court's decision for automated enforcement technology systems.

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