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Cain v. White

937 F.3d 446 (2019)

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Cain v. White

United States Court of Appeals for the Fifth Circuit

937 F.3d 446 (2019)

Facts

A Louisiana state statute established the judicial expense fund (JEF). About one quarter of the JEF funding came from the court’s collection of fines and fees. The judges had exclusive power to determine JEF spending. The money was used for a variety of expenses like support-staff salaries (but not judge compensation), office supplies, and building maintenance. If a criminal defendant failed to pay his court debts, the defendant received two written warning letters from the collections department, which had been established by the judges to administer the collection of fines and fees. If the debt remained unpaid, the collections department issued an alias capias warrant for contempt of court and set cash bail. After the present claim was filed, the judges reclaimed the power to issue warrants from the collections department, recalled almost all active warrants for unpaid fines and fees, and cancelled about $1 million in court debts. The judges became the persons issuing alias capias warrants for outstanding court debts. Several former criminal defendants, including Alana Cain, (plaintiffs) in Orleans Parish Criminal District Court (OPCDC) were assessed fines and fees after pleading guilty to various criminal offenses. The criminal defendants all failed to pay their fines and fees, and each was arrested and given a $20,000 bond. The judges did not consider the former criminal defendants’ abilities to pay their court debts before sending them to jail for failures to pay. The former criminal defendants filed suit in the district court, alleging that the OPCDC judges (defendants) had violated their due-process rights, among other claims. The district court found that the failure of the judges to provide a neutral forum for considering a criminal defendant’s ability to pay denied due process. The judges appealed to the United States Court of Appeals for the Fifth Circuit.

Rule of Law

Issue

Holding and Reasoning (Graves, J.)

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