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143164P.pdf 05/04/2016 Erik Mickelson v. County of Ramsey
U.S. Court of Appeals Case No: 14-3164
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Gruender, Author, with Wollman and Bye, Circuit Judges]
Civil Case - civil rights. Challenge to jail policy of deducting $25
booking fee from cash held by detainee upon booking does not violate
procedural due process, as the private interest in deprivation of $25 was
relatively modest and the county's interest in collecting fees at booking
is substantial to ensure collection. The policy allows for corrections of
any errors inherent in the overinclusive system of upfront collection and
any placing of onus on detainee to seek refund is not so cumbersome as to
undermine the constitutional adequacy of the post-deprivation refund
process. The post-deprivation process remedy suffices to pass
constitutional muster. Contention that any post-deprivation process was
inadequate is rejected. Plaintiffs did not allege the system was
inadequate. Judgment to defendants on the pleadings is affirmed. Use of
prepaid debit-card scheme for refund of cash, minus booking fee, does not
deprive procedural due process, as the use of a debit-card does not create
a constitutionally cognizable interest to trigger due process protections,
as distinction between cash and debit card is not constitutionally
significant, noting fees were both avoidable and minor.