Despite that, state judges continued to send people to jail for failing to pay court debts. that the Oregon courts would strike down the statute as being inconsistent with the constitutional provision if they faced the issue.). In fact, the recent bench card promulgated by Ohio Supreme Court Chief Justice OConnor begins as follows: Fines are separate from court costs. art. ^ Id. In addition, the ACLU asks for a "bench card" to remind judges in all courts across the state that jail is not a punishment for poverty. (5 Gray) at 532. Laws 941). "Murther, murther, murther, murther " shouted Free-born John Lilburne from prison. art. 1976) (en banc); Zeitinger v. Mitchell, 244 S.W.2d 91, 9798 (Mo. The ACLU charges that DeKalb County and the for-profit company Judicial Corrections Services teamed up to engage in a coercive debt collection scheme that focuses on revenue generation at the expense of protecting poor people's rights. Dir., ACLU of Colo. (Oct. 23, 2014) (notes on file with Harvard Law School Library); Telephone Interview with Alec Karakatsanis, Co-Founder, Equal Justice Under Law (Apr. 4:15-cv-00253 (E.D. 129, 130 (1838); Appleton v. Hopkins, 71 Mass. The late Professor William J. Stuntz also noted that regulatory crimes and core crimes like murder have dramatically different histories. Stuntz, supra, at 512. Stat. 2:14-cv-00186 (M.D. ^ Monsanto Co. v. Geertson Seed Farms, 130 S. Ct. 2743, 2761 (2010). L.Q. VI, 15 (No person shall be imprisoned for debt arising out of or founded upon a contract.). Donations from readers like you are essential to sustaining this work. The Debtors Act 1869 (32 & 33 Vict. In Lepak v. McClain, 844 P.2d 852 (Okla. 1992), the Oklahoma Supreme Court sustained the contempt-of-court power when used to require the delivery of . c. 62) was an Act of the Parliament of the United Kingdom of Great Britain and Ireland that aimed to reform the powers of courts to detain debtors . ^ To be found in the state bans of Arkansas, California, Iowa, Nebraska, New Mexico, Ohio, and Tennessee. This ACLU report presents the results of a year-long investigation into modern-day debtors' prisons in Louisiana, Michigan, Ohio, Washington, and Georgia. art. ^ Under Bearden, what counts as bona fide efforts was left unspecified, apart from vague references to searching for employment or sources of credit. 691, 691 (Iowa 1894). ^ See, e.g., William J. Stuntz, The Collapse of American Criminal Justice 2, 67 (2011); Karakatsanis, supra note 3, at 254; Natapoff, supra note 1, at 1065. The new American debtors prisons seem problematic along multiple dimensions. November 6, 2017 By: Bobby Casey, Managing Director GWP Do an internet search on debtors' prisons, and the top searches will J. Pub. ^ E.g., S.D. As much of the furor regarding contemporary debtors prisons revolves around municipalities, this is no minor point. One-Time Monthly Annual. ^ See, e.g., Ala. Const. ^ The 1849 Virginia statute took this approach, which was carried over into West Virginia when that state broke away from Virginia. Well never put our work behind a paywall, and well never put a limit on the number of articles you can read. For one, indigent debtors do not know whom to negotiate with the DMV, which mailed the speeding ticket, or the debt collector that now seems to be pursuing the matter. ^ See Settlement Agreement, Cleveland v. Montgomery, supra note 18, at 1. See, e.g., State v. Anton, 463 A.2d 703, 705 (Me. 560.031(5) (2000) ([T]he fine may be collected by any means authorized for the enforcement of money judgments.) (to be transferred to Mo. 833, 88687 (2013); Alexandra Natapoff, Misdemeanor Decriminalization, 68 Vand. ^ Id. If an offender or ex-offender fails to pay any of this debt, the court will outsource the debt to a private debt collector, and the process of taking the debtor to court, described above, begins all over again. Debt collection practices like these have had a devastating impact on people of color in the Atlanta metropolitan area. See id. VIII; id. Eventually, federal debtors' prisons were abolished in 1833, leaving the power to implement debtors' prisons in the hands of the states, many of which followed Washington's lead. The abolition movement certainly did not intend to exclude such debts from the ban; whether legislatures meant to include them depends upon how sparing ones assumptions about past intent are. 1951) (citing In re Clifts Estate, 159 P.2d at 876), and Oklahoma, see Sommer v. Sommer, 947 P.2d 512, 519 (Okla. 1997); Lepak, 844 P.2d at 855. The percentage of people living in poverty in Biloxi has doubled since 2009. ^ Id. Theres probably no principled reason to distinguish between attorneys fees and other costs, like a judgment fee or a clerk fee, but doctrinally the Court may have felt especially sensitive to discrimination with respect to assigning lawyers, given its recent decision mandating counsel for indigent defendants in Gideon v. Wainwright, 372 U.S. 335 (1963). Indeed, costs function more as fees for service or taxes than as punishments. But sometimes, the relevant statute explicitly tags the criminal justice debt as civil or as receiving civil protections.152, For example, in some jurisdictions, courts have held that violations of municipal ordinances constitute civil actions.153 In Kansas City v. Stricklin,154 for example, the Supreme Court of Missouri noted that these proceedings are not prosecutions for crime in a constitutional sense.155 Case law in a number of states supports this approach,156 although a fifty-state survey cannot be conducted here. . But, as argued below, the state bans on debtors prisons can supplement Bearden and they may well be relevant to the inquiry under James. See, e.g., Letter from Mark Silverstein, Legal Dir., ACLU of Colo., and Rebecca T. Wallace, Staff Atty, ACLU of Colo., to Chief Justice Michael Bender, Colo. Supreme Court, and Judge John Dailey, Chair, Criminal Procedure Comm. The Act of Congress established penal regulations and restrictions for persons jailed for property debt, tax evasion, and tax resistance. art. at 60. But the spirit behind them ought to drive other constitutional actors executives, legislators, and citizens to take swift action.167. at 26065; Becky A. Vogt, State v. Allison: Imprisonment for Debt in South Dakota, 46 S.D. Nearly two centuries ago, the United States formally abolished the incarceration of people who failed to pay off debts. . Thus, under James and Fuller, states cannot discriminate invidiously against at least some classes of criminal justice debtors (note that neither case involved fines) merely by virtue of the fact that the debts arise from a criminal proceeding. ^ See Note, Civil Arrest of Fraudulent Debtors: Toward Limiting the Capias Process, 26 Rutgers L. Rev. And other judges will consider all nonpayment to be willful, unless or until the debtor can prove that he or she has exhausted absolutely all other sources of income by quitting smoking, collecting and returning used soda cans and bottles, and asking family and friends for loans. They ultimately settled. 1, 11; Ga. Const. shall become a judgment in the same manner and to the same extent as any other judgment under the code of civil procedure.157 In Florida, convicted indigents assessed costs for due process services are expressly provided with the same protections as civil-judgment debtors.158 But not all collections statutes are so explicit, of course.159. ^ See, e.g., Colo. Const. I, 17; Wis. Const. In this process, indigent people who cannot afford to pay court fines and fees are routinely incarcerated in violation of their constitutional rights. I, 16; R.I. Const. (11 Allen) 264 (1865)). In other states, the court simply could not imprison for failure to pay the debt, although it could pursue other execution remedies available at law. art. the act of securing the money or property of another with a fraudulent intent . Below, seven frequently asked questions about the history and abolition of debtors' imprisonment, and its under-the-radar1 second act. ^ See ACLU, In for a Penny: The Rise of Americas New Debtors Prisons 17 (2010), http://www.aclu.org/files/assets/InForAPenny_web.pdf [http://perma.cc/2C7C-X56S] (Louisiana); id. Read More. Read more. The Twelve Tables, the oldest codification of Roman law we have, permitted its usage in 451 B.C. I, 17; Ariz. Const. A. James, 407 U.S. at 140 (quoting Rinaldi, 384 U.S. at 309). ^ E.g., In re Nichols, 749 So. The warrants charge debtors with failure to pay, order their arrest and jailing in the Harrison County Adult Detention Center, and explicitly state that debtors can avoid jail only if they pay the full amount of fines and fees in cash. ^ A more complete history would undoubtedly be helpful, but remains outside the scope of this Note. Now, the imprisonment-for-debt claims wouldnt challenge the propriety of assessing such charges in the first place. Eventually, federal debtors' prisons were abolished in 1833, leaving the power to implement debtors' prisons in the hands of the states, many of which followed Washington's lead. These warrants had led to the arrest and jailing of poor people struggling to pay criminal justice debt without any consideration for, or inquiry into, their ability to pay. The second is that the Supreme Court, in Bearden, did not define two key terms: indigent and willful. How are judges supposed to decide whether a debtor is indigent or, rather, is willfully refusing to pay? II, 18 (There shall be no imprisonment for debt, except in cases of fraud.). at 256 (citing Barnes v. State, 19 Conn. 398 (1849)). Instead of a test that asks whether the debtor has sought employment or credit per Bearden, in some states there would be a limited inquiry into whether the debtor possessed specific, nonexempt property that the debtor could be ordered to turn over. (citing Commonwealth v. Farren, 91 Mass. Many kinds of monetary obligations, then, have been held to fall outside the scope of the state bans. ^ A state, of course, could repeal its ban on debtors prisons, but any attempt to do so would create an unlikely coalition of criminal and civil debtors, and the political-action costs of doing so are likely too high. State and local courts have increasingly attempted to supplement their funding by charging fees to people convicted of crimes, including fees for public defenders, prosecutors, court administration, jail operation, and probation supervision. A debtors prison is any prison, jail, or other detention facility in which people are incarcerated for their inability, refusal, or failure to pay debt. She thought she might get a ticket. at 668. (10 Allen) 199 (1865); Commonwealth v. Waite, 93 Mass. 1915); Gooch v. Stephenson, 15 Me. . . diss., Harvard University, 1935). This imposes direct costs on the government and further destabilizes the lives of poor people struggling to pay their debts and leave the criminal justice system behind. Indeed, in People ex rel. at 56; see also William J. Stuntz, The Pathological Politics of Criminal Law, 100 Mich. L. Rev. See id. Debtors' prisons waste taxpayer money and resources by jailing people who may never be able to pay their debts. Second, even in states that allow contempt proceedings, most courts require a sharply limited (and debtor-favorable) inquiry. at 55 (Georgia); id. The problems posed by nineteenth-century debtors prisons in the United States differ in many ways from the challenges posed today by criminal justice debt. ^ See, e.g., Complaint, Jenkins v. Jennings, supra note 24, at 43 (The City prosecutor and City judge do not conduct indigence or ability-to-pay hearings. Yet, recent years have witnessed the rise of modern-day debtors' prisonsthe arrest and jailing of poor people for failure to pay legal debts they can never hope to afford, through criminal justice procedures that violate their most basic rights. F. 153 (2015), https://harvardlawreview.org/2015/11/state-bans-on-debtors-prisons-and-criminal-justice-debt-appendix. ^ For constitutional provisions, see, for example, Ariz. Const. at 855. The ACLU works in courts, legislatures, and communities to defend and preserve the individual rights and liberties that the Constitution and the laws of the United States guarantee everyone in this country. Part II covers a range of preexisting federal constitutional limitations on imprisonment for criminal justice debt. Speaker 505, 51314 (2001) (describing the massive growth in statutory offenses in several states from the second half of the nineteenth century until the early twenty-first century); cf. Murder is the crime, and help is the . I, 16; Wyo. Accessibility, A Christmas Carol and Other Christmas Books, The Collapse of American Criminal Justice, Investigation of the Ferguson Police Department, Criminal Justice Debt: A Barrier to Reentry, In for a Penny: The Rise of Americas New Debtors Prisons, Office of Judicial Servs., Supreme Court of Ohio, Collection of Fines and Court Costs in Adult Trial Courts, http://www.nytimes.com/2015/09/18/us/suit-alleges-scheme-in-criminal-costs-borne-by-new-orleanss-poor.html, http://aclu-wa.org/sites/default/files/attachments/Modern%20Day%20Debtor%27s%20Prison%20Final%20(3).pdf, http://www.newyorker.com/magazine/2014/06/23/get-out-of-jail-inc, http://www.splcenter.org/sites/default/files/downloads/case/amended_complaint-_harriet_cleveland_0.pdf, http://www.splcenter.org/sites/default/files/downloads/case/exhibit_a_to_joint_settlement_agreement_-_judicial_procedures-_140912.pdf, http://equaljusticeunderlaw.org/wp/wp-content/uploads/2015/02/Complaint-Jennings-Debtors-Prisons-FILE-STAMPED.pdf, http://www.justice.gov/sites/default/files/opa/press-releases/attachments/2015/03/04/ferguson_police_department_report.pdf, https://www.hrw.org/sites/default/files/reports/us0214_ForUpload_0.pdf, http://www.brennancenter.org/sites/default/files/legacy/Fees%20and%20Fines%20FINAL.pdf, https://assets.documentcloud.org/documents/2455850/15-10-09-class-action-complaint-stamped.pdf, http://www.nytimes.com/2015/10/20/us/for-offenders-who-cant-pay-its-a-pint-of-blood-or-jail-time.html. Most importantly, the 1983 decision in Bearden v. Georgia compelled local judges to distinguish between debtors who are too poor to pay and those who have the financial ability but willfully refuse to do so. I, 19; Kan. Const. Rev. ^ See id. A conference called by advocates for the abolition of debtors' prisons voted unanimously for resolutions2 including the understanding that . ^ See, e.g., Lee v. State, 75 Ala. 29, 30 (1883); Mosley v. Mayor of Gallatin, 78 Tenn. 494, 497 (1882). See Complaint, Cleveland v. Montgomery, supra note 14, at 23. for the enforcement of a judgment.); Mo. Read more. 4:15-cv-00252 (E.D. at 672. See sources cited supra note 95. ^ This possibility is made more credible by Justice OConnors note in the related case of Bearden v. Georgia that [d]ue process and equal protection principles converge in the Courts analysis in these cases. 461 U.S. 660, 665 (1983). ^ Bearden v. Georgia, 461 U.S. 660, 66869 (1983). International Covenant of Civil and Political Rights. ^ See, e.g., Harrison v. Harrison, 394 S.W.2d 128, 13031 (Ark. Dist. Given that we are looking at a substantial sales tax shortfall, its not an insignificant issue.44, In 2013, the municipal court issued over 9000 warrants for failure to pay fines and fees resulting in large part from minor violations such as parking infractions, traffic tickets, or housing code violations.45 The city also tacked on fines and fees for missed appearances and missed payments and used arrest warrants as a collection device.46, The problem has become especially severe or has at least drawn increased attention within the past several years.47 In 2015, nonprofits Equal Justice Under Law and ArchCity Defenders sued the cities of Ferguson48 and Jennings,49 Missouri, alleging that they were running the equivalents of modern debtors prisons.50 The Ferguson complaint described a Kafkaesque journey through the debtors prison network of Saint Louis County a lawless and labyrinthine scheme of dungeon-like municipal facilities and perpetual debt.51 Equal Justice Under Law and the Southern Poverty Law Center have also sued a handful of other municipalities,52 and the ACLU has pursued an awareness campaign in a number of states, sending letters to judges and mayors in Ohio53 and Colorado.54. 446, 447 (1846); State v. McCarroll, 70 So. ACLU Statement for U.S. Commission on Civil Rights Hearing on Municipal Policing and Courts: A Search for Justice or a Quest for Revenue. 489, 491 (1977) (State constitutions, too, are a font of individual liberties, their protections often extending beyond those required by the Supreme Courts interpretation of federal law. v. Rodriguez, 411 U.S. 1, 10506 (1973) (Marshall, J., dissenting); Johnson v. Bredesen, 624 F.3d 742, 749 (6th Cir. I, 1, XXIII (There shall be no imprisonment for debt.); Tex. And the problem is deeply engrained, at least in some places. ^ See Office of Judicial Servs., Supreme Court of Ohio, Collection of Fines and Court Costs in Adult Trial Courts (2015), http://www.supremecourt.ohio.gov/Publications/JCS/finesCourtCosts.pdf [http://perma.cc/43AE-V32F]; see also Taylor Gillan, Ohio Supreme Court Warns Judges to End Debtors Prisons, Jurist (Feb. 7, 2014, 7:14 AM), http://jurist.org/paperchase/2014/02/ohio-supreme-court-warns-judges-to-end-debtors-prisons.php [http://perma.cc/EA4L-BKHJ]. art. So, in 1833, Congress abolished the practice under federal law. at 57 (Douglas, J., concurring in the judgment). I, 21 (No person shall be imprisoned for debt arising out of or founded on contract, express or implied . 4:15-cv-00252 (E.D. .). It may leave too much discretion in the hands of the same legal actors responsible for the state of play. Most importantly, explains John Pollock, the coordinator of the National Coalition for a Civil Right to Counsel, indigent defendants have a right to counsel in criminal cases, but not in civil ones. art. ^ See id. Ala. Sept. 12, 2014) [hereinafter Settlement Agreement, Cleveland v. Montgomery], http://www.splcenter.org/sites/default/files/downloads/case/exhibit_a_to_joint_settlement_agreement_-_judicial_procedures-_140912.pdf [http://perma.cc/ZAH6-DFQS]. As the Ohio Supreme Court put it: In todays society, no one, in good conscience, can contend that a nine-dollar fine for crashing a stop sign is deserving of three days in jail if one is unable to pay.140. . You can also contribute via. See Charles Dickens, A Christmas Carol and Other Christmas Books 7172 (Robert Douglas-Fairhurst ed., Oxford Univ. ^ While constitutional carve-outs for fraud will capture some debtors, it cant plausibly lower the protections of the ban to the level of Bearden: the failure to search for a job or to seek credit is hardly fraudulent. Victims are told they can avoid jail only if they pay the entire amount of outstanding court fines and fees up front, in full, and in cash. Comeback of debtors' prisons: U.S. courts revive Dickensian practice of jailing people for failing to pay legal fees United States abolished debtors' prisons in the 1830s, but more than a third of . The courts had ordered their incarceration for non-payment of criminal justice debt without affording hearings to determine their abilitytopay or providing the option of paying through payment plans or community service. (9 Allen) 489 (1864)). I, 20; Alaska Const. Dir., ACLU of Ohio, et al., to Chief Justice Maureen OConnor, Ohio Supreme Court (Apr. art. Dec. 23, 2014) (en banc), http://www.courts.mo.gov/sup/index.nsf/d45a7635d4bfdb8f8625662000632638/fe656f36d6b518a886257db80081d43c [http://perma.cc/BTX3-4ERC]. Nevertheless, three specific kinds of criminal monetary obligations might actually be covered by the bans: fines for regulatory offenses, costs, and definitionally civil debts. . at 66162. art. In other words, poor people with debt face criminal consequences but without the Constitutional protections afforded to criminal defendants. Courts, however, did make clear that the legislature couldnt criminalize the mere nonpayment of commercial debt as a constitutional workaround. The report calls for a slate of reforms to end debtors prison practices. References: George Philip Bauer, "The Movement against Imprisonment for Debt in the United States" (Ph.D. 1679, 1679 n.1 (1971). ^ See Tate, 401 U.S. at 400; Williams, 399 U.S. at 242 n.19. ^ See Recent Legislation, supra note 23, at 1313, 1315. The ACLU and ACLU affiliates across the country have been exposing and challenging modern-day debtors' prisons across the country. Read More. App. Complaint, Fant v. Ferguson, supra note 48, at 53 (arguing governments may not take advantage of their position to impose unduly harsh methods of collection); Complaint, Jenkins v. Jennings, supra note 24, at 5859 (same). III, 30; Mo. Read more. I, 16; Vt. Const. v. Fritz, 449 U.S. 166, 179 (1980). Though de jure debtors prisons are a thing of the past, de facto debtors imprisonment is not. ^ For example, in 1855, Massachusetts passed a statute saying: Imprisonment for debt is hereby forever abolished in Massachusetts. Appleton, 71 Mass. Copyright 1887-2023 Harvard Law Review. . The report documents the realities of today's debtors' prisons, and provides state and local governments and courts with recommendations for pursuing sensible and fair approaches to collecting criminal justice debt. Yet Hall was critiquing a blind adherence to mens rea as a ubiquitous doctrine in criminal law. Read More. 1312, 1316 (2015). ^ The constitutional imprisonment-for-debt provisions are as follows: Ala. Const. 22-4513(a) (Supp. Oct. 9, 2015) [hereinafter Complaint, Bell v. Jackson], https://assets.documentcloud.org/documents/2455850/15-10-09-class-action-complaint-stamped.pdf [https://perma.cc/3CKT-XXX4] (describing reduction of debt at a rate of $58 per day of work); Karakatsanis, supra note 3, at 262 ($25 per day). Despite arising out of a criminal proceeding, costs are cleanly distinguishable from fines, restitution, and forfeiture in their basic purpose: compensating for or subsidizing the governments marginal expenditures on criminal proceedings. ^ State v. Blazina, 344 P.3d 680, 685 (Wash. 2015). 938.29(4) (2015) (specifying that such debtors shall not be denied any of the protections afforded any other civil judgment debtor). ^ See id. Also in this category are costs of imprisonment (billed to inmates in 41 states), and of parole and probation (44 states). 2d 227, 233 (Ala. Crim. ^ For an argument that awareness campaigns are more effective than litigation, see Eric Balaban, Shining a Light into Dark Corners: A Practitioners Guide to Successful Advocacy to Curb Debtors Prisons, 15 Loy. Id. See State v. Thierfelder, 495 N.W.2d 669, 673 (Wis. 1993); see also Wis. Stat. In Colorado, Linda Robertss offense of shoplifting $21 worth of food resulted in $746 of court costs, fines, fees, and restitution.37 Ms. Roberts, who lived exclusively on SNAP and Social Security disability benefits, sat out her debt by spending fifteen days in jail.38 And in Georgia, Tom Barrett was sentenced to twelve months of probation for stealing a can of beer.39 But six months in, despite selling his blood plasma, Barrett still couldnt pay the costs associated with his sentence including a $12-per-day ankle bracelet, a $50 set-up fee, and a $39-per-month fee to a private probation company and faced imprisonment.40 A 2010 Brennan Center report flagged problematic criminal justice debt practices in fifteen states, including California, Texas, Michigan, Pennsylvania, and New York.41 A 2010 ACLU report claimed that required indigency inquiries the heart of the constitutional protection provided by Bearden were markedly absent in Louisiana, Michigan, Ohio, Georgia, and Washington.42. For indigent people, a civil proceeding regarding private debt say, an unpaid payday loan may have criminal ramifications; conversely, involvement in a criminal case may create debt, causing a new civil proceeding. ^ See, e.g., State v. Hopp, 190 N.W.2d 836, 837 (Iowa 1971); In re Wheeler, 8 P. 276, 27778 (Kan. 1885). This concern is amplified by the growing trend toward outsourcing portions of the criminal justice system, such as collection, to private actors like Sentinel Offender Services, a probation company that wields the threat of imprisonment via contract with the state. at 42, 53. v. Murgia, 427 U.S. 307, 320 (1976) (Marshall, J., dissenting); San Antonio Indep. She was on probation because of a traffic violation. art. The issue reached the U.S. Supreme Court in the 1970s, with two cases in which the Court found it unconstitutional to incarcerate people solely because they could not pay a public debt (Williams v. Const. 556.061(29)) (defining infraction). . Read More. (It may be . See id. They are still generally accepted as such in this country. Jerome Hall, Prolegomena to a Science of Criminal Law, 89 U. Pa. L. Rev. Detail In England, debtors owing money could be easily detained by the courts for indefinite periods, being kept in debtor's prisons. ^ See, e.g., Telephone Interview with Nathan Woodliff-Stanley, Exec. The ACLU and ACLU affiliates are uncovering how debtors' prisons across the country undermine the criminal justice system and threaten civil rights and civil liberties. The report documents local courts that have a pattern of criminalizing poverty and perpetuating racial injustice through the unconstitutional enforcement of low-level offenses. 753, 767 (1943) (citing as generally accepted the maxim that an act does not make one guilty unless the mind is guilty). No matter what, you can always turn to The Marshall Project as a source of trustworthy journalism about the criminal justice system. . ^ It may also be worth pointing out that James and Fuller dealt most concretely with attorneys fees. The doctrinal carve-outs for crime suggest that the state bans wouldnt apply to criminal justice debt. monetary penalties imposed as a condition of a sentence, including, say, a traffic ticket; fees, which may include jail book-in fees, bail investigation fees5, public defender application fees, drug testing fees, DNA testing fees, jail per-diems for pretrial detention, court costs, felony surcharges, public defender recoupment fees, and on and on and on; and restitution, made to the victim or victims for personal or property damage. ^ Id. But some strict liability crimes, like statutory rape, are more easily analogized to traditional crimes despite the absence of a mens rea. Jailing the indigent for their failure to meet contractual obligations was considered primitive by ancient Greek and Roman politicians, and remains illegal and unheard of in most developed countries. L. Rev. (14 Gray) 324, 328 (1859). Regulatory offenses are assessed to deter low-level misbehavior, and costs are assessed to replenish the coffers of the criminal justice system, or to fund the government.
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