McKinley Brown, Etc. v. T. A. Vance, Etc., Mary Jean Boone, Etc., Cross-Appellee v. Walter L. Dennis, Etc., Cross-Appellants

637 F.2d 272
CourtCourt of Appeals for the Fifth Circuit
DecidedMarch 18, 1981
Docket78-3225
StatusPublished
Cited by52 cases

This text of 637 F.2d 272 (McKinley Brown, Etc. v. T. A. Vance, Etc., Mary Jean Boone, Etc., Cross-Appellee v. Walter L. Dennis, Etc., Cross-Appellants) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKinley Brown, Etc. v. T. A. Vance, Etc., Mary Jean Boone, Etc., Cross-Appellee v. Walter L. Dennis, Etc., Cross-Appellants, 637 F.2d 272 (5th Cir. 1981).

Opinions

WISDOM, Circuit Judge:

These consolidated class actions challenge the statutory fee system for compensating justice court judges (justices of the peace)1 in the State of Mississippi.2 Brown v. Vance involves criminal cases; Boone v. Dennis involves civil cases.3 The plaintiffs concede that the pertinent statutes are constitutional on their face, apparently because the judges are paid regardless of the outcome of the cases. They contend, however, that the system is unconstitutional, as ap- . plied, for lack of due process. A judge’s compensation depends on the number of cases filed in his court. The plaintiffs allege that police officers favor “convicting judges”; collection agencies and other creditors favor judges who tend to decide in their favor. The system, therefore, according to the plaintiffs/appellants, produces a temptation to the average man as a judge to favor conviction in criminal cases and judgment for the plaintiffs in civil cases.

The district court held that the plaintiffs had failed to carry the burden of overcoming the presumption of honesty and integrity in those serving as adjudicators. On appeal, the plaintiffs/appellants abandon their state-wide attack in Brown; they maintain, however, that they met their bur[275]*275den of proof in criminal cases in districts where two judges have concurrent jurisdiction. Hinds and DeSoto counties have such districts. On appeal the plaintiffs/appellants in Boone adhere to their position that the civil fee system throughout the State is unconstitutional. We reverse in part and affirm in part.

I.

Each of Mississippi’s 82 counties is divided into five districts, and a justice court judge is elected from each, except that a county having over 200,000 inhabitants may have one additional judge for each district. Miss. Code Ann. § 9-11-1. Only Hinds County, which includes the City of Jackson, and DeSoto County, just south of Memphis, have two judges for each district. Under § 171 of the Mississippi Constitution and § 99-33-1 of the Mississippi Code, justice court judges in Mississippi have jurisdiction over misdemeanors occurring in their districts. If no judge is qualified and available in the district where the violation occurred, the case can be heard by any judge in the county. Id. The judges have jurisdiction over all civil actions in which the amount of damages or the value of the property involved does not exceed $500. Id. § 9-11-9. Jurisdiction in civil cases is coextensive with the county. Venue is proper in the district where the debt occurred, where the defendant resides, or where the property is located. Id. § 11-9-101. Objections to venue are waived if not raised by the defendant. Stanley v. Cruise, 1924, 134 Miss. 542, 99 So. 376.

Justice court judges in Mississippi do not receive a salary. At the time when these suits were brought and tried a judge received $6 for each criminal case docketed and affidavit signed, regardless of the disposition of the case. Id. § 25-7-25. The judge received $8 in each civil case, contested or uncontested, payable by the losing party. Id. Additionally, each judge received $8 in civil cases for proceedings involving levy of execution on judgments and attachment and garnishment proceedings. Id. Since the trial of this case, the Mississippi legislature has increased the judges’ compensation. Judges now receive $15 for each civil case and $10 for each criminal case. Id. (1979 Cum. Supp.). There is no longer any fee for postjudgment proceedings in a civil case.

At trial the plaintiffs did not limit their evidence to criminal cases in Hinds and DeSoto counties, but attacked the entire criminal fee system. They contended that in the eighty counties where there was one judge to a district officers would patrol, set roadblocks, and make arrests in districts having a high conviction rate; when officers made arrests in a district where there was a low conviction rate, the traffic tickets were often made returnable to another district.

The plaintiffs argue that most civil suits are filed by collection agencies and businesses having a heavy volume of litigation. Creditors shop for a favorable forum and choose the judge most likely to find for plaintiffs. Because judges used to receive an extra fee for certain postjudgment proceedings, they had a compound pecuniary interest in granting a judgment for the plaintiffs.

The trial judge’s findings were favorable to the defendants. He found that few officers made arrest tickets returnable to a judge in a district where there was no jurisdiction. The Mississippi Commissioner of Public Safety testified that disciplinary measures are taken against any patrolmen who return tickets to a district other than that in which the violation occurred. The district court also found that the use of roadblocks and radar was not limited to districts in which judges have high conviction rates. Highway patrolmen instead used “a computerized scientific formula” based upon many factors, including prime accident and high fatality areas, high violation points, and safety factors for the officers and motoring public. Some judges continued to receive tickets even though on occasion they had found defendants not guilty or had dismissed charges. The district court rejected documentary and testimonial evidence about the disparity be[276]*276tween fees received by judges in different districts, finding that “the genesis of this disparity is [in the] difference in highway mileage, types and classes of roads, traffic counts, accident and fatality rates, and seasonal traffic variations”.

The district court found that judges transferred civil cases when the defendant raised the question of improper venue. Moreover, creditors continued to use judges who had found in favor of defendants or had entered judgment for less than the plaintiff demanded. Some forum shopping existed, but one witness testified that efficiency and judicial experience were two of the primary elements creditors considered in deciding where to file suit. Statistics submitted by the plaintiffs did not show the number or percentage of cases when venue was waived or when the cases were transferred, dismissed, or resulted in a determination in favor of the defendant. On these findings, the district court concluded that the fee system in civil actions did not violate due process.

The district judge held that due process was violated by the additional $8 fee for postjudgment proceedings involving levy of execution on judgments and attachment and garnishment proceedings. The fee gave “[a] Justice Court Judge ... an unconstitutional pecuniary interest in favoring plaintiffs who file civil suits in his court”. On cross-appeal the State argues that the district court erred in holding that the fee system for postjudgment proceedings in civil cases violates due process.

II.

In considering the Mississippi fee system the relevant constitutional fact is that a judge’s bread and butter depend on the number of cases filed in his court. Traditionally, justices of the peace who handle petty criminal cases and small claims are close to the general public and are an important, if not essential, element in any state’s system of justice.

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Cite This Page — Counsel Stack

Bluebook (online)
637 F.2d 272, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinley-brown-etc-v-t-a-vance-etc-mary-jean-boone-etc-ca5-1981.