Carrick v. Beebe, No. 14-1954 (8th Cir. 2015)
Annotate this CaseThe City of Little Rock issued Carrick three citations for violating municipal ordinances. In Arkansas, such citations, if contested, are initially tried to a judge and can be appealed to a jury in the state trial court, Ark. Code 16-96-112. Carrick contested the citations and was found guilty of two violations following the initial bench trial. The court imposed no punishment. Carrick then appealed to a jury, paying a $150 filing fee and a $15 "technology fee," both of which are non-refundable. After an initial mistrial, the case against Carrick was dismissed. Carrick sought a refund of the fees. The Arkansas Court of Appeals affirmed denial of a refund; the Arkansas Supreme Court denied review. Carrick filed suit under 42 U.S.C. 1983, alleging violations of the Arkansas Constitution, Arkansas statutes, and the Fifth, Sixth, and Fourteenth Amendments of the U.S. Constitution. The district court denied relief. The Eighth Circuit affirmed, rejecting an argument that the non-refundable fees served as impermissible barriers to the exercise of his Sixth Amendment right to a jury trial because Carrick had no Sixth Amendment right to a jury trial regarding his alleged ordinance violations.
Court Description: Civil case - Civil rights. Plaintiff had no Sixth Amendment right to a jury trial on his citations for violating municipal ordinances because they were not serious offenses, and his Sixth Amendment and ancillary due process claims fail.
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