OUR STRATEGY: This declaration may look unbelievably complicated, but it really isn’t. One of the big problems people have in defending themselves against an automated enforcement ticket is that the underlying math involved seems so difficult, that their brain shuts down and retreats to that lonely stupid place that brains go when confronted with numbers.
Well kids, its time to strap on a pair of math cajones and figure how hard Lockheed Martin is screwing you with their evil cyclopean robots. Bottom line about all this math: you can trigger the cameras even though you legally crossed the limit line on yellow. How? The embedded sensors that trigger the camera are ahead of the limit line, which can cause a vehicle crossing the line on yellow to still be photographed and cited for crossing the sensors on red. Even the “statement of technology” offered by Big Brother fails to mention that the triggering sensors are ahead of the limit line.
A decent argument can be made that drivers cited for running a red light by 0.2 to 1.0 seconds actually began legally crossing the limit line on yellow but triggered the camera with their back tires as the light turned red.
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STATEMENT OF FACTS
Defendant’s Name: Virginia Woolf
Case No.: S780824
I respectfully submit this written declaration to the Court pursuant to CVC 40902. I plead Not Guilty to the charge of violating CVC 21453(c).
On 9/8/99 at approximately 11:35, I entered the intersection of Garnet Ave at Mission Bay Drive in Pacific Beach. The light was clearly yellow when I crossed the near side limit line as I entered the intersection. CVC 21453(c) states: A driver facing a steady red arrow… shall stop at a clearly marked limit line… .” The arrow was still yellow when I crossed the limit line; I did not violate this law.
The automated enforcement notice I received provides two data boxes with information about my alleged offense. The first box is the most important, as it records how long the light was red before my vehicle passed over the embedded sensors in the road. CVC 21453(c) mentions the limit line only: it makes no mention of embedded sensors. I know I crossed the limit line on yellow; the sensors are another issue.
The embedded sensors are not located under the limit line. If they had been, a picture would have never been taken since I crossed the limit line on yellow, not red. The sensors are located in front of the limit line at the entrance to the intersection. As a result, the first data box is only indicating how long the light was red when I crossed over the sensors, which are well ahead of the limit line: the data does not indicate that the light was red when I crossed the limit line.
Two formulas are provided in the “statement of technology” issued with the ticket. 1) 1.47ft (distance traveled per second for each mile per hour) X speed of your vehicle = DPS (distance per second). 2) DPS X R (elapsed time at the beginning of the violation) = distance behind the stop bar when the light turned red. The second formula is incorrect in one respect: DPS X R is really the distance behind the embedded sensors when the light turned red. Nowhere on the “statement of technology” is the distance from the sensors to the limit line (i.e. how many feet ahead of the limit line the sensors are located) ever provided. I’ll name this distance DSLL (distance from sensors to limit line). This distance from the sensors to the limit line must be subtracted from the DPS X R calculation to get the true “distance behind the stop bar when the light turned red.” So the correct formula here would be DPS X R= distance behind sensors when the light turned red – DSLL (distance from sensors to limit line) = true distance behind stop bar when light turned red. Failure to note that DSLL must be subtracted to get the correct distance and failure to provide this vital information in my notice to appear is a clear manipulation of this already confusing data by those charged with ensuring the fairness of this system and should be, in itself, grounds for dismissal of this citation. In my case: 1.47ft X 25mph= 36.75 ft/second (DPS). 2) 36.75ft/sec X .4sec (4/10 of a second, elapsed red time in first data box) = 14.7 ft (distance behind sensors when light turned red). The first photo taken shows my large van almost completely across the limit line. My van itself is almost 15 feet long. If the distance between the sensors and the limit line (DSLL) is more than 14.7 ft, then it is clear that I am innocent of this charge. I am confident that I started across the limit line on yellow and not red.
The failure of the automated enforcement notice to indicate and subtract DSLL (distance from sensors to limit line) in its calculations, should cast serious doubt on their commitment to fairly and honestly administer this questionable technology and enforcement program. I am not guilty of running a red light; please do not give this questionable ticket the support of the court and the law. Please dismiss my citation in the interest of justice.
If the court does not find in my favor in this case, I request a Trial de Novo.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
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