the creation of a unique investigatory tool, the fake "ticket." Groups opposing the use of red light cameras have argued that where the cameras are not set up to identify the vehicle driver, owner liability issues are raised. It is perceived by some that the owner of the vehicle is unfairly penalized by being considered liable for red-light violations although they may not have been the driver at the time of the offense. In most jurisdictions the liability for red light violations is a civil offense, rather than a criminal citation, issued upon the vehicle owner—similar to a parking ticket. The issue of owner liability has been addressed in the US courts, with a ruling in the District of Columbia Court of Appeals in 2007, which agreed with a lower court when it found that the presumption of liability of the owners of vehicles issued citations does not violate due process rights. This ruling was supported by a 2009 7th US Circuit Court of Appeals ruling in which it was held that issuing citations to vehicle owners (or lessees) is constitutional. The court stated that it also encourages drivers to be cautious in lending their vehicles to others. The argument that red light cameras violate the privacy of citizens, has also been addressed in the US courts. According to a 2009 ruling by the 7th US Circuit Court of Appeals, "no one has a fundamental right to run a red light or avoid being seen by a camera on a public street." In addition, cameras only take photographs or video when a vehicle has run a red light and, in most states, the camera does not photograph the driver or the occupants of the vehicle. It is also argued that such cameras violate the Sixth Amendment's Confrontation Clause and the right to be assumed innocent until proven guilty. In most areas, red light enforcement cameras are installed and maintained by private firms. Lawsuits have been raised challenging private companies' rights to hand out citations, such as a December 2008 lawsuit challenging the city of Dallas' red light camera program, which was dismissed in March 2009. In most cases, citations are issued by law enforcement officers using the evidence provided by the companies. There have been many instances where cities in the US have been found to have too-short yellow-light intervals at some intersections where red light cameras have been installed.