Bearden v. Professor Jerome Hall, writing in 1941, said: [The act requirement] and the mens rea principle constituted the two most basic doctrines of [Bishops] treatise on criminal law. . 1679, 1679 n.1 (1971). I, 16; Wyo. Rev. 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. Imprisonment for nonpayment of contractual debt was a normal feature of American commercial life from the colonial era into the beginning of the nineteenth century.93 But with the rise of credit testing and the replacement of personal lending networks with secured credit, imprisonment for nonpayment came to be seen as a harsh and unwieldy sanction,94 and a growing movement pressed for its abolition. In 2013, the ACLU of Ohio issuedOutskirts of Hope, a report documenting blatantly illegal debtors' prisons around the state. ^ Id. Second, costs. at 60. 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.
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