Kelvin Leon Jones v. Governor of Florida
975 F.3d 1016 (2020)
Rule of Law:
States may constitutionally condition the restoration of a convicted felon's voting rights on the completion of all terms of their sentence, including the payment of fines, fees, costs, and restitution, and such requirements are subject to rational basis review rather than heightened scrutiny.
Facts:
- Historically, the Florida Constitution disenfranchised all persons convicted of felonies until their civil rights were restored.
- In 2018, Florida voters passed Amendment 4, which automatically restored voting rights to felons (excluding those convicted of murder or sexual offenses) upon 'completion of all terms of sentence.'
- Following the amendment, the Florida Legislature enacted Senate Bill 7066, which statutorily defined 'completion of all terms of sentence' to include full payment of all restitution, fines, fees, and costs imposed in the sentencing document.
- The State of Florida lacks a centralized database to track legal financial obligations, often making it difficult for felons to determine exactly how much they owe.
- The State adopted an 'every-dollar method' policy where any payment made in relation to a sentence is credited toward the original obligation, even if the money actually went to third-party collection fees.
- A significant percentage of disenfranchised felons in Florida are indigent and unable to pay the outstanding financial obligations required to regain their vote.
- At the time of trial, approximately 85,000 felons had registered to vote under Amendment 4, but the State had not yet completed screening them for eligibility based on financial obligations.
Procedural Posture:
- Felons sued Florida state officials in the U.S. District Court for the Northern District of Florida challenging the pay-to-vote requirement.
- The District Court entered a preliminary injunction in favor of the plaintiffs.
- A panel of the U.S. Court of Appeals for the Eleventh Circuit affirmed the preliminary injunction.
- The District Court certified a class of plaintiffs and held a bench trial on the merits.
- The District Court entered a permanent injunction declaring the law unconstitutional as applied to those unable to pay.
- Florida officials appealed the final judgment to the U.S. Court of Appeals for the Eleventh Circuit, which granted initial hearing en banc.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state law requiring convicted felons to pay all legal financial obligations (fines, fees, costs, and restitution) before regaining the right to vote violate the Equal Protection Clause, the Due Process Clause, or the Twenty-Fourth Amendment's prohibition on poll taxes?
Opinions:
Majority - Chief Judge William Pryor
No, the requirement does not violate the Constitution because states have broad discretion to define the terms of felon reenfranchisement. The court reasoned that felons do not have a fundamental right to vote, as the Fourteenth Amendment explicitly permits felon disenfranchisement (Richardson v. Ramirez). Because wealth is not a suspect classification, the law is subject only to rational basis review. The state has a legitimate interest in ensuring that felons fully pay their debt to society and are fully rehabilitated before voting. Additionally, the court held that court costs and fees are criminal penalties, not taxes, and therefore do not violate the Twenty-Fourth Amendment. Regarding due process, the court held that the legislative process itself provides sufficient notice for generally applicable laws, and vagueness concerns are mitigated by the scienter requirement for illegal voting.
Concurring - Judge Lagoa
Yes, the law is constitutional, and heightened scrutiny is inappropriate because Florida provides alternative avenues for rights restoration. The concurrence emphasized that indigent felons are not absolutely deprived of the franchise because they can seek executive clemency, judicial modification of sentences, or conversion of financial obligations to community service. Therefore, the law does not discriminate solely based on inability to pay.
Dissenting - Judge Jordan
No, the law is unconstitutional because it effectively disenfranchises citizens based solely on their wealth. The dissent argued that heightened scrutiny should apply under Griffin and Bearden because the state is punishing indigent felons more harshly than wealthy ones. Even under rational basis review, the dissent argued the scheme fails because the state's administrative inability to track amounts owed makes the system irrational and arbitrary, acting essentially as a poll tax.
Dissenting - Judge Martin
No, the law violates due process because the state's administrative system prevents citizens from knowing if they are eligible to vote. The dissent characterized the implementation as an 'administrative train wreck,' arguing that conditioning voting rights on factual determinations (amount owed) that the State itself cannot accurately calculate or communicate to the voter violates the basic requirements of due process.
Dissenting - Judge Jill Pryor
No, the law is unconstitutional because it nullifies the will of the Florida voters who passed Amendment 4. The dissent emphasized that the legislature's imposition of financial barriers effectively blocks the vast majority of intended beneficiaries from regaining their rights, creating a pay-to-vote system that ignores the reality of widespread indigence among the formerly incarcerated.
Analysis:
This en banc decision creates a significant precedent regarding the scope of state power over felon reenfranchisement. It firmly establishes that wealth-based classifications in the context of restoring voting rights to felons trigger only rational basis review, rejecting the application of the 'heightened scrutiny' typically applied in indigency cases involving fundamental rights (like Bearden). The decision strictly limits the application of the Twenty-Fourth Amendment, clarifying that financial penalties associated with criminal sentences are not 'taxes.' Broadly, this ruling signals judicial deference to state legislatures in defining 'completion of sentence,' even when administrative difficulties make compliance hard for indigent citizens.
Gunnerbot
AI-powered case assistant
Loaded: Kelvin Leon Jones v. Governor of Florida (2020)
Try: "What was the holding?" or "Explain the dissent"