Harris v. Heckers

Summary

The Colorado Supreme Court reviewed the constitutionality of Colorado's implied-consent law governing driver's-license suspension for refusing chemical sobriety tests. The court held that the statute's differing treatment of licensed residents, nonresidents, and residents without licenses had a rational basis and did not violate equal protection. The judgment was reversed and the case remanded for consideration of other alleged errors.

Holdings

1. The statute's semicolon divides the provision into two classes: residents with licenses and nonresidents, whose six-month period runs from the hearing, and residents without licenses, who are denied issuance of a license for six months from the date of the alleged violation.
2. The statutory distinction between residents with licenses and nonresidents, on the one hand, and residents without licenses, on the other, was rational and did not violate equal protection.
3. Courts must presume statutes constitutional, and a party challenging a statute must prove its invalidity beyond a reasonable doubt.

Questions Presented

1. Whether the implied-consent statute required different six-month suspension start dates for residents and nonresidents.
2. Whether the statutory classification treating residents with licenses and nonresidents differently from residents without licenses violated equal protection.
3. Whether the district court properly declared the implied-consent statute unconstitutional.

Disposition

reversed_and_remanded