Plaintiff, a 20 year old college student, was sentenced to jail because he was unable to pay a $206 statutory fine with $33 in court costs for throwing a cigarette butt out of his car window. He made approximately $135 a week as a line cook and was unable to pay the fine in full. In his appearance before the judge, he pled guilty but asked if he could perform community service instead of paying the fine or be placed on a payment plan. The court informed him that there were no alternatives and he needed to pay the fine in full. Unable to pay and having no one who would pay the fine for him, the plaintiff was sentenced to jail for five days. Plaintiff argued that the judge violated his due process and equal protection rights by sentencing him to jail solely because he was unable to pay the court fines and fees.
The court agreed the defendant’s Fourteenth Amendment rights were violated. Further, the court found that the Township of Burlington could be held liable, despite their claims of immunity, but that it did not have enough material facts to find the judge liable. Also, the court allowed the plaintiff to amend and add the Municipal Court Administrator as a defendant. Thus, plaintiff’s summary judgment motion was partially granted. Parties later appeared to reach a settlement but failed to submit the papers and the judge dismissed the case with prejudice.
You can read the opinion here.