This case alleged that the City of Biloxi operated a debtor’s prison, routinely jailing indigent people who could not afford to pay fines and fees imposed in traffic and misdemeanor cases.
Harrison County Jail was a modern day debtors’ prison. Officers went to predominantly African American neighborhoods arbitrarily checking people to see if they had paid their court fines and fees.
An indigent's equal protection rights are violated when defendants can avoid prosecution by paying a fine, without determining an individual’s ability to pay the fine.