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Timbs v. Indiana

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Supreme Court of the United States
Timbs v. Indiana
Term: 2018
Important Dates
Argument: November 28, 2018
Decided: February 20, 2019
Outcome
Indiana Supreme Court vacated and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh
Concurring
Clarence Thomas • Neil Gorsuch

Timbs v. Indiana is a case argued before the Supreme Court of the United States on November 28, 2018, during the court's 2018-2019 term. The case concerned the Eighth Amendment’s ban on excessive fines.

In a unanimous ruling, the court vacated and remanded the opinion of the Indiana Supreme Court, holding that "the Eighth Amendment’s Excessive Fines Clause is an incorporated protection applicable to the States under the Fourteenth Amendment’s Due Process Clause."[1][2]

HIGHLIGHTS
  • The case: When Tyson Timbs pleaded guilty to a drug charge, he was ordered as part of his sentence to forfeit his Land Rover, on the grounds that he had transported drugs in the vehicle. A state appeals court ruled in favor of Timbs, who argued that the forfeiture was unconstitutional under the Eighth Amendment's clause prohibiting excessive fines. The Indiana Supreme Court reversed the decision, stating that the U.S. Supreme Court had never ruled that the excessive fines clause applied to state governments.
  • The issue: Whether the Eighth Amendment's Excessive Fines Clause is incorporated against the States under the Fourteenth Amendment.[3]
  • The outcome: The court vacated and remanded the opinion of the Indiana Supreme Court, holding that "the Eighth Amendment’s Excessive Fines Clause is an incorporated protection applicable to the States under the Fourteenth Amendment’s Due Process Clause."[2]


    • Why it matters: The case clarified that the Eighth Amendment's clause prohibiting excessive fines applies to state governments.

    You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • February 20, 2019: U.S. Supreme Court vacated and remanded Indiana Supreme Court's ruling
    • November 28, 2018: Oral argument
    • June 18, 2018: U.S. Supreme Court agreed to hear case
    • January 31, 2018: Petition filed with U.S. Supreme Court
    • November 2, 2017: Indiana Supreme Court reversed lower court’s ruling

    Background

    Federalism
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    •Key terms
    •     Court cases
    •Major arguments
    • State responses to federal mandates
    • Federalism by the numbers
    • Index of articles about federalism

    Tyson Timbs was arrested in 2013 and charged with two counts of dealing in controlled substances and one count of conspiracy to commit theft. He accepted a plea deal in which he pleaded guilty to the conspiracy to commit theft charge and one count of dealing in controlled substances. The third charge was dismissed. He was sentenced to six years with five suspended. He also paid various fines and fees totaling $1,203. The state also sought to forfeit his Land Rover, which Timbs had purchased for $42,058 because he had used the vehicle to transport drugs. The district court denied the state's action, ruling, "The amount of the forfeiture sought is excessive, and is grossly disproportional to the gravity of the Defendant’s offense."[4]

    An Indiana appeals court affirmed the district court's decision. The case was further appealed to the Indiana Supreme Court, which reversed the lower court's ruling. The state supreme court's ruling stated, "Only after ratification of the Fourteenth Amendment did the Supreme Court, in the early twentieth century, begin to apply various provisions of the Bill of Rights to the States through the doctrine of selective incorporation". The court concluded, "The Supreme Court has never held that States are subject to the Excessive Fines Clause."[4]

    Timbs appealed to the U.S. Supreme Court, and the court agreed to hear the case on June 18, 2018.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Whether the Eighth Amendment's Excessive Fines Clause is incorporated against the States under the Fourteenth Amendment.

    Oral argument

    Oral argument in the case was held on November 28, 2018.

    Audio

    • Audio of oral argument:[5]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Justice Ruth Bader Ginsburg delivered the unanimous opinion of the court. The court vacated and remanded the opinion of the Indiana Supreme Court, holding that "the Eighth Amendment’s Excessive Fines Clause is an incorporated protection applicable to the States under the Fourteenth Amendment’s Due Process Clause."[2]

    Opinions

    Opinion of the court

    In her opinion for the court, Justice Ginsburg wrote,

    “ The Fourteenth Amendment’s Due Process Clause incorporates and renders applicable to the States Bill of Rights protections 'fundamental to our scheme of ordered liberty,' or 'deeply rooted in this Nation’s history and tradition.' McDonald v. Chicago, 561 U. S. 742, 767 (alterations omitted). If a Bill of Rights protection is incorporated, there is no daylight between the federal and state conduct it prohibits or requires.[6] ”

    Concurring opinions

    Justice Neil Gorsuch filed a concurring opinion. Justice Clarence Thomas filed an opinion concurring in the judgment.

    Justice Neil Gorsuch, who joined the court's opinion, wrote, “There can be no serious doubt that the Fourteenth Amendment requires the States to respect the freedom from excessive fines enshrined in the Eighth Amendment.”[7]

    Justice Clarence Thomas "agreed that the ban on excessive fines applies to the states, but he would have reached that result in a different way. Instead of relying on the due process clause of the 14th Amendment, Thomas would hold that the ban on excessive fines is 'one of the ‘privileges or immunities of citizens of the United States’ protected by the Fourteenth Amendment,'" according to SCOTUSblog.[7]

    Text of the opinion

    • Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-1091 Timbs v. Indiana," accessed October 31, 2018
    2. ↑ 2.0 2.1 2.2 2.3 United States Supreme Court, "Timbs v. Indiana," Opinion, February 20, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "QPReport 17-1091 Timbs v. Indiana," accessed October 31, 2018
    4. ↑ 4.0 4.1 4.2 SCOTUSblog, "Timbs v. Indiana," accessed October 31, 2018
    5. ↑ Supreme Court of the United States, Timbs v. Indiana, argued November 28, 2018
    6. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ 7.0 7.1 SCOTUSblog, "Opinion analysis: Eighth Amendment’s ban on excessive fines applies to the states," February 20, 2019
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