Andrew Grimm v. City of Portland

Portland, Oregon constitutional law lawyer represented the Plaintiff challenging Portland's ordinance authorizing towing of vehicle.



Andrew Grimm parked a car on the side of a downtown street in the City of Portland, Oregon, paid for an hour and

19 minutes of parking through a mobile app, and then left the car on the street for seven days. During that time, City

parking enforcement officers issued multiple parking citations, which they placed on the car's windshield. After

the car had sat on the street for five days, a parking enforcement officer added to this growing pile a slip warning

that the car would be towed. Grimm did not move the car and, two days after the warning slip was placed on the

windshield, the car was towed.4 G RIMM V. CITY OF PORTLAND Grimm sued the City, alleging that its procedures for

notifying him that his car would be towed were deficient under the Fourteenth Amendment's Due Process Clause.



The district court granted summary judgment to the City. The district court explained that, although Grimm's failure

to remove the citations from the windshield might have alerted the City that its attempt to provide notice had failed,

no other form of notice was practicable under the circumstances.

The City conformed with the requirements of the Furteenth Amendment by providing notice reasonably calculated to alert Grimm of the impending tow. We further

hold that Grimm’s failure to remove the citations and warning slip from the windshield did not provide the City with actual knowledge that its attempt to provide notice had failed.