The first question that came to mind upon reading this was: "are lawyers involved in the contest letter filing process? If not, I wonder if they may have a problem re: unauthorized practice of law in CA.
All it takes is to submit a letter. Doesn't say who has to submit the letter.
I assume they've looked at legal ethics decisions before they opened for business. But who knows, start ups sometimes cut legal corners.
They may just have supervising attorney's who double check all the work before it goes out the door. A lot of small firms have teams of paralegals who do paperwork and one attorney who signs off.
In CA it's defined as: 'As the term is generally understood, the practice of the law is the doing or performing services in a court of justice, in any matter depending therein, throughout its various stages, and in conformity to the adopted rules of procedure. But in a larger sense it includes legal advice and counsel, and the preparation of legal instruments and contracts by which legal rights are secured although such matter may or may not be depending in a court.'
My fiance got a ticket on Muni that was clearly in error (her Clipper Card record showed her tagging 9 minutes prior to the ticket being issued). We followed the instructions for submitting a protest, and never heard back. After some back and forth, it seemed like the protest process was just /dev/null-ed, so we paid up just to make the problem go away.
My take-away was that if you wanted to actually fight a citation you'd have to take them to court. As I understand it, fare evasion was a criminal offense until a few years ago, when they decriminalized it in favor of the new citation system, in order to save money on court costs.
It also changes the requirement from "proof beyond a reasonable doubt" to "the preponderance of the evidence", a much lower standard.