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Minnesota Supreme Court Halts Confinement Fees for Pre-Conviction Inmates
The Minnesota Supreme Court held in December 2009 that pre-conviction prisoners residing in county jails or similar facilities could not be required to pay costs of confinement.
Andrew Tyler Jones stayed 286 days in Olmsted County Jail awaiting resolution of his case. He pled guilty to three counts of aggravated robbery in November 2004. The county billed Jones $7,150 for pre-conviction confinement costs. Jones, indigent, filed suit challenging the county’s right to levy those charges.
At issue was the wording of the Minnesota statute that the county jail used as its authority. Olmsted County Sheriff Steven C. Borchardt contended that the wording of the statute under scrutiny allowed him to retroactively assess fees from prisoners held in county jail once they had been convicted. The district court granted Sheriff Borchardt’s motion for summary judgment and the court of appeals affirmed.
The Minnesota Supreme Court parsed the statute de novo. The court noted that the object of statutory interpretation is to ascertain and actuate legislative intent, construing words and phrases according to the rules of grammar, noting also that clear and unambiguous wording cannot be assigned an alternate meaning to fit someone’s idea of the spirit of the law.
In the case at bar both parties focused on the same phrase within the meaning of the statute, “offender convicted of a crime and confined in the county jail,” each defining that phrase in accordance with their argument – Jones asserting that it meant county jails may levy costs after conviction only; Sheriff Borchardt insisted the wording defined the two conditions necessary to levy costs, conviction and confinement, regardless of when they occurred.
The Supreme Court of Minnesota noted that the operative word in the statute was “offender.” Jones was a non-offender until his conviction, according to Black’s Law Dictionary, and he never was an offender until his conviction and his pre-conviction confinement costs were not an offender’s expense.
The Supreme Court of Minnesota reversed and remanded. See: Jones v. Borchardt, 775 N.W.2d 646 (Minn. 2009).
Andrew Tyler Jones stayed 286 days in Olmsted County Jail awaiting resolution of his case. He pled guilty to three counts of aggravated robbery in November 2004. The county billed Jones $7,150 for pre-conviction confinement costs. Jones, indigent, filed suit challenging the county’s right to levy those charges.
At issue was the wording of the Minnesota statute that the county jail used as its authority. Olmsted County Sheriff Steven C. Borchardt contended that the wording of the statute under scrutiny allowed him to retroactively assess fees from prisoners held in county jail once they had been convicted. The district court granted Sheriff Borchardt’s motion for summary judgment and the court of appeals affirmed.
The Minnesota Supreme Court parsed the statute de novo. The court noted that the object of statutory interpretation is to ascertain and actuate legislative intent, construing words and phrases according to the rules of grammar, noting also that clear and unambiguous wording cannot be assigned an alternate meaning to fit someone’s idea of the spirit of the law.
In the case at bar both parties focused on the same phrase within the meaning of the statute, “offender convicted of a crime and confined in the county jail,” each defining that phrase in accordance with their argument – Jones asserting that it meant county jails may levy costs after conviction only; Sheriff Borchardt insisted the wording defined the two conditions necessary to levy costs, conviction and confinement, regardless of when they occurred.
The Supreme Court of Minnesota noted that the operative word in the statute was “offender.” Jones was a non-offender until his conviction, according to Black’s Law Dictionary, and he never was an offender until his conviction and his pre-conviction confinement costs were not an offender’s expense.
The Supreme Court of Minnesota reversed and remanded. See: Jones v. Borchardt, 775 N.W.2d 646 (Minn. 2009).
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Related legal case
Jones v. Borchardt
| Year | 2009 |
|---|---|
| Cite | 775 N.W.2d 646 (Minn. 2009) |
| Level | State Supreme Court |