Law School Case Brief
Timbs v. Indiana - 139 S. Ct. 682 (2019)
Like the Eighth Amendment's proscriptions of cruel and unusual punishment and excessive bail, the protection against excessive fines guards against abuses of government's punitive or criminal-law-enforcement authority. This safeguard is fundamental to our scheme of ordered liberty, with deep roots in our history and tradition. The Excessive Fines Clause is therefore incorporated by the Due Process Clause of the Fourteenth Amendment.
Defendant Tyson Timbs pleaded guilty in Indiana state court to dealing in a controlled substance and conspiracy to commit theft. At the time of Timbs' arrest, the police seized a Land Rover SUV that Timbs had purchased for $42,000 with money he received from an insurance policy when his father died. The State sought civil forfeiture of the vehicle, charging that the SUV had been used to transport heroin. Observing that Timbs had recently purchased the vehicle for more than four times the maximum $10,000 monetary fine assessable against him for his drug conviction, the trial court denied the State’s request. The vehicle's forfeiture, the court determined, would be grossly disproportionate to the gravity of Timbs’ offense, and therefore unconstitutional under the Eighth Amendment’s Excessive Fines Clause. The Court of Appeals of Indiana affirmed, but the Supreme Court of Indiana reversed, holding that the Excessive Fines Clause constrained only federal action and was inapplicable to state impositions.
Was the Eighth Amendment's Excessive Fines Clause an incorporated protection applicable to the States under the Fourteenth Amendment's Due Process Clause?
The Supreme Court of the United States held that the Eighth Amendment’s Excessive Fines Clause is an incorporated protection applicable to the States under the Fourteenth Amendment’s Due Process Clause. The Court reasoned that protection against excessive punitive economic sanctions secured by the Excessive Fines Clause is both fundamental to our scheme of ordered liberty and deeply rooted in the nation's history and tradition. Furthermore, the Court ruled, in considering whether the Fourteenth Amendment incorporates a Bill of Rights protection, the Court asks whether the right guaranteed—not each and every particular application of that right—is fundamental or deeply rooted. Thus, the Excessive Fines Clause is incorporated regardless of whether application of the Clause to civil in rem forfeitures is itself fundamental or deeply rooted. The Court vacated the judgment of the Supreme Court of Indiana and remanded the matter for further proceedings.
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