Civil Practice : Standing – Red Light Camera – Unjust Enrichment

Where drivers sued the City of Des Moines and the operator of its automated traffic enforcement system arguing that a red light camera system violated federal and state law, the drivers’ receipt of a violation notice constituted sufficient injury in fact to establish standing, but an administrative hearing was optional rather than required, and the drivers failed to state an unjust enrichment claim.

Judgment is affirmed in part; reversed in part; remanded.

Brooks v. City of Des Moines (MLW No. 69959/Case No. 15-2781 – 5 pages) (U.S. Court of Appeals, 8^th Circuit, Benton, J.) Appealed from U.S. District Court, Southern District of Iowa, Wolle, J. (James C. Larew, Iowa City, Iowa, argued for appellant) (Thomas George Fisher, Des Moines, Iowa, argued for appellee).

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