Medford and its police department responded Wednesday to a local chiropractor’s lawsuit that alleges an illegal “photo red-light trap” potentially led to thousands of drivers receiving illegitimate traffic citations.

In a 15-page filing, Dominic Campanella, a private Medford-based attorney representing the city and the Medford Police Department, denied the accusations made by chiropractor Glenn Gumaer and three other plaintiffs, who filed a civil complaint in Jackson County Circuit Court on Jan. 17.

On Thursday, Eric Mitton, attorney for the city of Medford, issued a statement, saying that while the city is still investigating the lawsuit’s claims, “we are confident” the case will be dismissed.

“The City has complied with the laws governing the operation of traffic lights,” Mitton said.

Gumaer told the Rogue Valley Times in a phone interview he has received the city’s response, but has not had time to fully analyze it.

After a preliminary glance, Gumaer called the response “a nothing burger” and said it was standard procedure for the city.

“They don’t have a strong case. They don’t have any affirmative defense — and you can’t defend against mathematics when you can use solid math and prove that the light was timed too short,” Gumaer said.

Gumaer and the other plaintiffs ask a jury to award up to $10 million in damages related to drivers’ red-light violations at the three-way intersection of East Barnett Road and Stewart Avenue in Medford.

Gumaer drove his sports car through the intersection in January 2022 and received a citation, which he challenged in Medford Municipal Court. Gumaer alleged then, and alleges now, that the yellow light lasted just three and a half seconds, creating a so-called “driver dilemma zone” that made it impossible for motorists to safely stop or provide enough time to perform the right turn without hitting a red light.

The city later announced it decided to drop Gumaer’s citation “due to a technicality” and said it had updated yellow light timings from 3.5 seconds to 5.1 seconds to “increase fairness” at three intersections, including at East Barnett Road and Stewart Avenue.

Despite these developments, Gumaer expressed interest in filing a class-action lawsuit. He told the Rogue Valley Times earlier this year that he is bringing the litigation in good faith.

But in a Wednesday filing, Campanella argued that Gumaer and the other plaintiffs failed in even the most basic ways in filing the lawsuit.

Campanella said the statute of limitations ran out by the time the parties filed and that they did not provide timely notices of the lawsuit to the city under the Federal Tort Claims Act.

Campanella also argued that Gumaer and the plaintiffs’ case should not proceed as a class-action lawsuit because their claims are “not common” and “potential conflict” exists between the plaintiffs and anyone else who might join the litigation. Campanella’s filing did not elaborate on this point.

Campanella also argued that Gumaer and the plaintiffs’ claims are barred under a legal theory that prevents a party from re-litigating a claim once a court has issued a final judgment on that claim. Though Campanella did not mention it, a Municipal Court judge had issued a reduced fine for Gumaer’s traffic violation before the city dismissed it, according to previous news reports.

Campanella argued that the city acted appropriately in issuing citations based on a photo red-light system and followed state statute when it operated the traffic control device at the intersection of East Barnett Road and Stewart Avenue.

Campanella said the city and its police department are both immune from liability.

Gumaer said his next steps will likely be to request information from the city and submit questions that officials would be required to answer. Any court hearing is down the road, he said.