Earlier this month, the U.S. Supreme Court released an opinion in an interesting case requiring the Court to interpret the Eighth Amendment’s Excessive Fines Clause. Specifically, the court was tasked with deciding whether the rights contained in the Excessive Fines Clause were incorporated through the Fourteenth Amendment, and thus applicable to proceedings in state court. Ultimately, the court concluded that the rights granted by the Excessive Fines Clause were incorporated and thus applied to state court criminal trials, such as the one in this case.
The details of the defendant’s arrest were not particularly relevant to the Court’s inquiry. In short, police pulled over the defendant while he was operating a Land Rover SUV that he had recently purchased with the proceeds from an insurance policy. Police arrested the defendant for possession with the intent to deliver narcotics, as well as conspiracy to commit theft.
The defendant pleaded guilty and received a sentence of one year of in-home detention, then five subsequent years of probation. Additionally, he was fined approximately $1,200. After the case, the state government sought civil forfeiture of the defendant’s vehicle, claiming that it was used in the commission of a crime. The lower court rejected the government’s request, stating that the vehicle’s value was over four times greater than the maximum allowable fine that could have been imposed against the defendant, and that such a forfeiture would be excessive under the Eighth Amendment’s prohibition against excessive fines.
The state supreme court reversed the trial court’s judgment, permitting the forfeiture. That court held that the Excessive Fines Clause of the Eighth Amendment only applied to federal actions, and not to state-court proceedings. The defendant appealed.
The Court’s Decision
In an opinion by Justice Ginsburg, the court held that the rights contained within the Excessive Fines Clause were incorporated through the passage of the Fourteenth Amendment and applied to state-court proceedings such as the one at issue in this case. The Court explained that before the Fourteenth Amendment, the rights contained in the Bill of Rights were enforceable only against the federal government. However, the Due Process Clause of the Fourteenth Amendment incorporated a majority of the rights included in the Bill of Rights, making them applicable to the states.
The court explained that the Fourteenth Amendment incorporated all rights that were “fundamental to our scheme of ordered liberty,” with “deep roots in our history and tradition.” The court noted that the underpinnings of the Excessive Fines Clause date back to Magna Carta. From there, the court documented the importance of the protection against excessive fines as it pertained to the formation of the Country, ultimately concluding that the right to be free from excessive fines was deeply rooted in our nation’s history and “fundamental to our scheme of ordered liberty.” Thus, the Court reversed the state supreme court’s decision.
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