The State of Confusion has established the Red Light Camera Agency ("RLCA") to assist its courts in doling out punishment to those filmed breaking traffic laws. The RLCA promulgated rules that required automatic suspension of state issued drivers licenses based on registered ownership of the vehicle filmed, with only a post determination hearing available. Bob loaned his car to his 16 year old son Junior who ran a red light. Bob holds a CDL and makes his living as an over the road truck driver. Junior, ashamed and scared, fails to tell Bob about the ticket. Two months later, after the date to enter a plea has come and gone - Bob gets a notice in the mail that is license his suspended. His employer requires self reporting of any change in the status of his CDL. After advised of the administrative suspension, Bob is terminated because he no longer holds a valid CDL.

Bob comes to you (his lawyer) and complains the result wasn't fair and that he wasn't the one driving at the time the red light was run. Using the analysis you lean red in PLS 651 on whether due process requires a pre-determination or post determination hearing - explain what you plan to argue to help Bob.