By: Associated Press
February 15, 2020
ATLANTA (AP) — Federal appeals court judges said they were “deeply troubled” that a Georgia municipal court jailed a woman when she couldn’t pay a fine for driving without insurance.
A three-judge panel of the 11th U.S. Circuit Court of Appeals upheld the dismissal of Ziahonna Teagan’s claims that her civil rights were violated, but said she could pursue a false imprisonment claim against the city of McDonough, news outlets reported.
“We are deeply troubled by what happened to Ms. Teagan in the McDonough municipal court,” the unsigned opinion says. “She, like all other citizens of that city, deserved better.”
After Teagan pleaded not guilty in December 2013, Judge Donald Patten found her guilty during a bench trial in March 2014. He imposed a $745 fine for driving without insurance and a $50 fine for arriving late to court.
Teagan told the judge she couldn’t immediately pay the fine but would be able to pay just over a week later. Patten sentenced her to serve 60 days in jail, suspending the sentence on the condition that she pay the total amount within nine days.
When she missed that deadline, Patten added $100 charge for contempt and signed a warrant for her arrest. She was arrested on May 18, 2014, and spent 12 days in jail. She was released when her brother paid the $895.
The 11th Circuit ruling said Patten never asked Teagan why she didn’t pay or whether she was able to pay.
In addition to the unsigned opinion Tuesday, Judge Adalberto Jordan wrote a concurring opinion in which he admonished the court in McDonough, which is about 30 miles (48.2 kilometers) southeast of Atlanta. Longstanding precedent says municipal courts can’t jail people to compel the payment of a fine, he wrote, calling what happened to Teagan “impossible to defend and difficult to understand.”
“Jailing a defendant for failing to pay a fine — without any determination that her failure to pay was willful — is a flagrant violation of the U.S. Constitution,” he wrote. “A municipal court cannot shirk its duties to protect indigent defendants’ constitutional rights in order to line its city’s coffers.”
Noting that the municipal court in McDonough had taken in $7.4 million in fines since 2012, he wrote that “one wonders how much of that sum was secured through unconstitutional means.”
Harvey Gray, a lawyer who represents the city, told The Atlanta Journal-Constitution the court was right to uphold the dismissal of most of Teagan’s claims. He said he’d made the city aware of what the 11th Circuit said about jailing people who couldn’t pay fines.
A city spokeswoman deferred questions to Patten, who told the newspaper that he couldn’t comment while Teagan’s case was still pending.
Lawyer Robert Remar, who represents Teagan, told the Journal-Constitution that he’s concerned courts will continue to jail people who can’t pay.
“It’s unfortunate the court was not able to address the clear constitutional violations that resulted in Ms. Teagan spending 12 days in jail because she was unable to pay a fine,” Remar said. “Without allowing any remedy, it allows courts to continue operating like this in an unconstitutional manner.”
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