Perhaps one might consider, as a plaintiff seeking to litigate a substantial and critical constitutional law case, that their attorney should, you know, know the law
"Mr. Neuharth has the highest rate of set asides on Drivers' License suspensions according to DMV statistics, published pursuant to the Freedom of Information Act." (http://paulneuharth.com
Fascinating statistic. However, California has no "Freedom of Information Act." It does, however, have a Public Records Act
(Cal. Govt. Code section 6250, et seq.).
Something I would think a lawyer bringing such a substantial and critical constitutional law case might not overlook. Or a well-researched plaintiff, for that matter.