Mendoza v. Strickler

The State is “free to choose” a variety of measures less intrusive than incarceration, and does not have to accept a defendant escaping punishment for lack of ability to pay a fine. See Williams v. Illinois, 399 U.S. 235, 244–45 (1970); Bearden v. Georgia, 461 U.S. 660, 672 (1983).

Under a since repealed state system, Petitioner’s driver’s license was suspended, based on her failure to pay traffic fines, without first assessing her ability to pay the fines. ORS § 809.210(1)(a) (2019). Petitioner argued that she was too poor to pay the fines required to reinstate her driver’s license, implicating Due Process, Equal Protection and hightened judicial scrutiny. Her complaint was dismissed for failure to state a claim. While dealing with “access to justice,” cases cited by Petitioner in support of her claim do not establish a heightened scrutiny requirement for indigent defendants unable to pay non-judicial fees: “driver’s license” fees are explicitly used as a counterexample. See Griffin v. Illinois, 351 U.S. 12 (1956); M.L.B. v. S.L.J., 519 U.S. 102, 124 n.14 (1996). The State is “free to choose” a variety of measures less intrusive than incarceration and does not have to accept a defendant escaping punishment for lack of ability to pay a fine. See Williams v. Illinois, 399 U.S. 235, 244–45 (1970); Bearden v. Georgia, 461 U.S. 660, 672 (1983). Petitioner’s non-carceral fine was not converted into incarceration, and she was not denied access to judicial procedures, making the correct judicial standard rational basis. Suspending Petitioner’s license is rationally related to the State’s legitimate interest in the punishment and deterrence of traffic violations. Affirmed.