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Law & Justice

Idaho Supreme Court Sends Warning Shot To Counties Jailing Those Who Can't Pay Court Fines

An empty courtroom at the Idaho Supreme Court
James Dawson
/
Boise State Public Radio
A courtroom at the Idaho Supreme Court.

A new ruling from the state’s highest court could reshape the way counties across Idaho deal with people who don’t, or aren’t able to, pay their court fines.

Last year, an Elmore County judge issued a warrant for Roxana Beck, saying she failed to pay about $650 in court fines related to a past misdemeanor conviction.

Beck was eventually arrested in Canyon County in October and held in jail for five days – two days longer than the maximum sentence. She eventually entered an Alford plea, meaning she maintained her innocence, but acknowledged prosecutors could likely prove their case.

Beck was given credit for time served and was given another payment plan.

In December, she asked the Idaho Supreme Court to issue a “writ for prohibition” against Elmore County from enforcing future warrants in these circumstances.

“Essentially what you’re saying is that the government or the party against whom you’re seeking this writ has no authority to act or that they’ve exceeded their authority to act,” said University of Idaho Law professor Shaakirrah Sanders.

The other factor the Idaho Supreme Court had to consider, Sanders said, was whether or not there was no other way Beck could solve this issue, like by filing a lawsuit.

The five justices unanimously ruled in Beck’s favor last week and took the unusual step of issuing the writ.

“[The Elmore County Magistrate court] effectively turned a fine into jail time without due process,” the opinion reads.

It said the county’s warrant was unconstitutional for several reasons, including that the judge never verified Beck’s ability to pay the fines.

She had been working at Burger King during her sentencing hearing for the initial misdemeanor conviction, which is what the county pointed to as evidence Beck was employed, but willfully avoided paying her fine months later.

The Idaho Supreme Court found that violated Beck’s 14th Amendment rights. The 1983 U.S. Supreme Court Case Bearden v. Georgia requires courts must prove that a defendant is refusing to pay their fines before a warrant for contempt can be issued.

Sanders said the decision contrasts with Idaho’s conservative reputation.

“For many, this could read like a progressive criminal justice opinion, right? And the idea that that would come out of the same state that is seeking to ban critical race theory is interesting.”

Elmore County updated its criminal contempt policy just one week after Beck asked the Idaho Supreme Court to take up the case and argued that it rendered her argument moot.

Justices welcomed the changes, but said Beck’s case still had merit, as well as “…there is substantial public interest in addressing the issues presented in this case.”

“We recognize that other counties in Idaho may also have antiquated procedures for addressing a defendant’s failure to pay fines and fees that do not take into account the constitutional evolution that has occurred in recent years,” the opinion reads.

Elmore County could appeal the decision to the U.S. Supreme Court. A spokesperson for the attorney general’s office declined to comment on the case.

Follow James Dawson on Twitter @RadioDawson for more local news.

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