The Eighth Circuit Court of Appeals has revived a lawsuit filed by former inmates Leticia Roberts and Calvin Sayers against Black Hawk County and Sheriff Tony Thompson. The court ruled on May 20, 2026, that the county's practice of requiring inmates to sign confessions of judgment for jail fees may violate their due process rights under the Fourteenth Amendment. This decision could have significant implications for how counties across the U.S. collect fees from inmates.

Roberts and Sayers, who served time in the Black Hawk County Jail, claimed that the county's method of collecting jail fees was unconstitutional. They argued that the practice deprived them of their property without adequate legal process. The court's ruling allows their case to proceed, which could lead to changes in how jail fees are collected in Iowa and potentially beyond.

Background

The plaintiffs in this case, Leticia Roberts and Calvin Sayers, are former inmates of Black Hawk County Jail in Iowa. Both were incarcerated for operating a vehicle while intoxicated. Upon their release, they were required to sign confessions of judgment, which acknowledged their debt for jail fees. The county charges inmates $70 per day for their stay, plus a $25 booking fee. If inmates do not pay these fees, the county typically would need to file a civil claim to recover the money.

However, rather than following the civil reimbursement process, Black Hawk County has implemented a policy that requires inmates to sign confessions of judgment before being released. This practice allows the county to collect unpaid fees without a court hearing. Roberts and Sayers filed their lawsuit under 42 U.S.C. § 1983, claiming that the county's actions violated their due process rights by denying them a fair opportunity to challenge the fees.

The district court initially dismissed their claims, stating that Roberts and Sayers lacked standing and had not sufficiently stated a claim for relief. The court found that their injuries were not directly tied to the county's actions, as they would have owed jail fees regardless of the confessions of judgment. This dismissal prompted Roberts and Sayers to appeal the decision to the Eighth Circuit.

The Ruling

The Eighth Circuit Court of Appeals, composed of Judges Loken, Gruender, and Grasz, reviewed the case and reversed the district court's decision. The court found that Roberts and Sayers did have standing to pursue their claims. The judges noted that both plaintiffs had suffered an injury-in-fact due to the county's practices, which deprived them of their property without due process.

The court ruled, "Roberts and Sayers plausibly allege the County actually deprived them of their interests in their money without due process, so they both allege an injury-in-fact."

The court emphasized that the confessions of judgment created a significant risk for the plaintiffs, as they felt compelled to make payments to avoid further legal action from the county. The judges also pointed out that the county's practice of requiring confessions of judgment denied inmates the opportunity to contest the fees in a court of law, which is a violation of due process.

Furthermore, the court found that the district court had erred in concluding that Roberts and Sayers had voluntarily paid their jail fees. The Eighth Circuit stated that the circumstances surrounding the confessions of judgment indicated coercion, as the inmates were required to sign them to regain their personal belongings upon release.

Impact

The Eighth Circuit's ruling has significant implications for the collection of jail fees in Black Hawk County and potentially across the nation. If the plaintiffs succeed in their claims, it could lead to changes in how counties handle inmate fees. The court's decision highlights the importance of due process rights for individuals in the criminal justice system, particularly regarding financial obligations imposed during incarceration.

This case could set a precedent for other jurisdictions that employ similar practices. If the court ultimately finds that the county's policy is unconstitutional, it may prompt a reevaluation of jail fee collection methods across the country, ensuring that inmates have a fair opportunity to contest such fees.

What's Next

The case has been remanded to the district court for further proceedings. It remains to be seen whether Black Hawk County will appeal the Eighth Circuit's decision. Additionally, the court will need to address the merits of Roberts and Sayers' claims regarding the constitutionality of the confessions of judgment and the county's fee collection practices.