Livingood v. City of Des Moines

Ruled that the city’s use of income tax refunds to offset automated traffic citation penalties did not constitute an unconstitutional taking of plaintiffs’ income tax refunds. Also held that the city’s attempts to enforce civil penalties for automatic traffic citations did not violate vehicle owners’ due process rights where owners were provided with notices of violation, notice of city’s intent to transfer matter to income offset program, and notices of intent to offset—and owners failed to seek hearings in response to each of those notices