The federal appeals court in Atlanta on Tuesday said it was “deeply troubled” by the way McDonough’s municipal court jailed a woman who was unable to pay a fine for driving without car insurance.
A three-judge panel of the 11th U.S. Circuit Court of Appeals expressed its dismay even though it ruled in the city's favor in dismissing all but one of Ziahonna Teagan's claims. Writing separately, Judge Adalberto Jordan strongly condemned McDonough's court for ignoring clearly established law.
“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,” Jordan wrote. “A municipal court cannot shirk its duties to protect indigent defendants’ constitutional rights in order to line its city’s coffers.”
Jordan noted that McDonough’s municipal court had generated $7.4 million in revenue from fines since 2012. “Given Ms. Teagan’s experience, one wonders how much of that sum was secured through unconstitutional means,” the judge said.
In December 2013, Teagan appeared in court and pleaded not guilty. On March 19, 2014, Judge Donald Patten held a bench trial and found Teagan guilty. He fined her $745 for driving without insurance and $50 for being late to court.
When Teagan told Patten she could not pay the fines that day but would be able to nine days later, Patten sentenced her to 60 days in jail, which was suspended on the condition she pay the $795 by March 28, 2014.
When Teagan missed the deadline, Patten signed a warrant to have her arrested and tacked on a $100 “contempt charge” as well. The judge never asked Teagan why she failed to pay or whether she had the ability to do so, the 11th Circuit ruling said.
Teagan was arrested at her home on May 18, 2014, and jailed. She was released 12 days later when her brother came up with the $895.
Teagan filed a civil rights suit against the city, but U.S. District Judge Eleanor Ross in Atlanta dismissed her claims. On Tuesday, the 11th Circuit found that Patten, when presiding over Teagan’s case, was acting on behalf of the state, not the city. For that reason, the city cannot be held liable for what happened, the court said.
The 11th Circuit did keep Teagan's claim of false imprisonment alive, sending it back to Ross so she could give it more consideration. The three judges on the 11th Circuit panel — Jordan, Gerald Tjoflat and Lanier Anderson — also let the city know how they felt.
“We are deeply troubled by what happened to Ms. Teagan in the McDonough municipal court,” they said. “She, like all other citizens of that city, deserved better.”
Longstanding legal precedent prohibits municipal courts from using imprisonment to coerce the payment of a fine, Jordan wrote in his separate opinion. “What happened to Ms. Teagan is therefore impossible to defend and difficult to understand.”
Jordan added, "This practice, which does not appear to be isolated throughout municipal courts in Georgia, flouts the venerable and longstanding principle that debtors' prisons are unconstitutional."
Atlanta lawyer Robert Remar, who represents Teagan, said Jordan was right on that point.
“But 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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Atlanta lawyer Harvey Gray, who argued the case for the city, said the court ruled the right way.
If a defendant can sue a city based on decisions by a municipal judge acting under state authority, “you’d have to close the courts down,” he said. Gray added that he had conveyed to the city the 11th Circuit’s thoughts on the practice of jailing indigent defendants unable to pay their fines.
Trisha Colpetzer, a spokeswoman for the McDonough mayor’s office, deferred questions to Patten on how he runs his courtroom. Patten, when contacted Thursday, said he could not comment while Teagan’s case was still pending.
