Susan Tomai-Minogue v. State Farm Mutual Automobile Insurance Company

WILKINSON, Circuit Judge:

This is the latest variation on a much-litigated theme: due process and the driver’s license. A modern property interest, unknown to the horsedrawn and steam powered societies that debated the Fifth and Fourteenth Amendments, a driver’s license may not, once granted, be taken by the state without due process of law. The question is how much process is due. Here we conclude that the Virginia statute requiring suspension of licenses where motorists have failed to satisfy accident judgments affords sufficient procedural protection.

The Virginia Commissioner of Motor…