A federal appeals court has breathed new life into a lawsuit challenging how an Iowa county collects fees from jail inmates, ruling Wednesday that two former prisoners can proceed with their constitutional claims against Black Hawk County’s jail fee collection practices.
The Eighth Circuit Court of Appeals reversed a lower court’s dismissal of the case, finding that former inmates Leticia Roberts and Calvin Sayers have standing to challenge the county’s system of collecting $70 per day in incarceration costs plus a $25 booking fee.
At the center of the dispute is Black Hawk County’s practice of having inmates sign what is called a “confession of judgment” – a legal document that commits them to paying the fees upon release without the ability to challenge the collection in court. This approach bypasses the standard Iowa procedure, which requires counties to file civil reimbursement claims that undergo judicial review if released inmates don’t pay voluntarily.
Roberts, a single mother of three from Waterloo, Iowa, signed the sheriff’s confession of judgment document when she was released from jail, believing she had no alternative. Two years later, she continues working to pay off the $730 debt. Both Roberts and Sayers argue the practice violated their 14th Amendment due process rights by denying them an opportunity to contest the fees in court.
The case had initially been dismissed in November 2024 by Chief U.S. District Judge C.J. Williams, who determined the inmates had not been deprived of their property and had voluntarily paid the jail fees. However, the three-judge appellate panel disagreed with this assessment.
U.S. Circuit Judge Raymond Gruender, writing for the panel, explained that without these confessions of judgment, the county would need to pursue jail fee collection through the standard civil reimbursement process, which would give prisoners the chance to challenge the fees in state court. The judge noted that the plaintiffs plausibly alleged the county deprived them of their property interests without due process, establishing an injury-in-fact.
The appeals court also determined that Roberts and Sayers have standing to seek both injunctive and declaratory relief against the county’s collection process. The panel found that because the policy remains in effect and the confessions of judgment are still in the county’s possession, there exists a real and immediate threat that the county could file these confessions, resulting in additional deprivations without adequate process.
“Because we assume that Roberts and Sayers would be successful on the merits, we assume that the county’s use of confessions of judgment is constitutionally inadequate process,” Judge Gruender wrote in the opinion.
The panel, which included U.S. Circuit Judge James Loken and U.S. Circuit Judge L. Steven Grasz alongside Gruender, remanded the case back to the lower court for further proceedings. This decision means the former inmates’ class action lawsuit can move forward as they seek to challenge the constitutionality of the county’s fee collection methods.
The Black Hawk County Sheriff’s Office declined to provide comment on the ruling Wednesday, citing the ongoing litigation. The case represents a broader challenge to jail fee collection practices and raises questions about the constitutional limits on how counties can recover incarceration costs from former inmates.
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