A. Does the driver license restoration regime established in New York violate Petitioner's right to due process of law because DMV, although given legislative permission, writes the rules, administers the rules, and adjudicates the application of those rules? All of these steps are conducted by either employees or appointees of the DMV and the only hearing is conducted on the papers submitted by the applicant. Furthermore, judicial review is conducted after the administrative proceedings and is circumscribed by the deference the court must give to the administrative agency, thereby denying Petitioner review by an independent magistrate.

B. Does the driver license restoration regime deny Petitioner equal protection of the law because there is no method to determine if Petitioner is treated differently than other similarly situated applicants for driver license restoration?

C. Does the license restoration regime violate the separation of powers so as to deny Petitioner access to an independent judiciary?

D. Does the license restoration regime constitute the unconstitutional taking of property either because it is an additional penalty for prior criminal acts or is punishment disproportionate to the underlying civil action.

Whether New York's driver license restoration regime violates due process by allowing the DMV to write, administer, and adjudicate its own rules without independent judicial review