Hilda Brucker, et al. v. City of Doraville, No. 21-10122 (11th Cir. 2022)
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Plaintiffs accused the City of Doraville, Georgia, of violating their right to due process. Each of the four Plaintiffs received citations from the City for traffic or property code violations and were ordered to pay fines and fees by the municipal court. They allege that this process presented an unconstitutional risk of bias because the City’s budget heavily relies on fines and fees, and this reliance could encourage the judge, prosecutor, and law enforcement agents—all paid by the City—to overzealously enforce the law. On appeal, Plaintiffs argued that Doraville’s prosecutor has a financial incentive to bring more cases because, like the judge, his income supposedly depends on his ability to generate revenue for the City.
The Eleventh Circuit affirmed the district court’s grant of summary judgment to the City finding that Plaintiffs have not raised a genuine issue of material fact concerning the bias of Doraville’s judge, its prosecutor, its police, or its code enforcement agents. The court held while unwise for a government to rely on fines and fees to balance its budget, the importance of fines and fees to a city’s budget does not make its procedures for imposing fines and fees unconstitutional.
The court explained that the fact a judge works for a government, which gets a significant portion of its revenues from fines and fees, is not enough to establish an unconstitutional risk of bias on the part of the judge. Further, given the relaxed standard of impartiality for prosecutors, Plaintiffs have presented inadequate evidence that the prosecutor had a personal financial interest.
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