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Williams v. Illinois

Facts of the Case

Provided by Oyez

Willie E. Williams was convicted for theft of credit cards, checks, and papers worth less than $150. He received the maximum sentence for petty theft in Illinois: one year of imprisonment and a $500 fine. If Williams was unable to pay the fine (and an additional $5 in court costs) at the end of his sentence, he would remain in jail to “work off” the fine at a rate of $5 per day.

While in jail, Williams petitioned the trial court to vacate the “work off” provision of his sentence. Williams argued that he did not have any money or property with which to pay the money portion of his sentence, but he would pay if released after one year and allowed to get a job. The trial court held that Williams’ ability to pay might change by the end of his sentence and dismissed his petition. Williams appealed directly to the Supreme Court of Illinois and argued that the denial of his petition violated his right to equal protection of the laws under the Fourteenth Amendment. The court held that there was no Fourteenth Amendment violation.

Questions

  1. Is the Equal Protection Clause of the Fourteenth Amendment violated when an impoverished defendant is imprisoned to satisfy payment of a fine and court costs?

Conclusions

  1. Justice John M. Harlan wrote a concurring opinion in which he argued that the Illinois law was impermissible under the Due Process Clause of the Fourteenth Amendment rather than the Equal Protection Clause because the latter ruling would place a substantial burden on states to create a system of individualized fines. Additionally, the Equal Protection clause allowed judges to substitute their opinions for those of the legislature, while the Due Process Clause placed legislation that deprives an individual of his right to remain free under higher judicial scrutiny. Justice Harlan determined that the state interests in forcing someone without assets to “work off” their fines as opposed to using a payment plan or other alternative are administrative convenience and better crime deterrence, but that these interests cannot justify depriving poor individuals of their liberty.