Markadonatos v. Village of Woodridge

Dist. Ct. did not err in dismissing for failure to state cause of action plaintiff’s putative class action lawsuit under section 1983, challenging on procedural and substantive due process grounds defendant-Village’s collection of $30 booking fee from plaintiff, who had been arrested by Village police, but who had eventually been found “not guilty“ on charged offense. Under Mathews balancing test, instant booking fee did not violate plaintiff’s procedural due process rights since defendant’s interest in offsetting costs of holding plaintiff temporarily outweighed plaintiff’s interests in his $30, where there was exceedingly low likelihood that fee would be imposed erroneously on plaintiff or other arrestees. Moreover, plaintiff had other state remedies available to him to address any risk of false arrest that would provide means for plaintiff’s recovery of booking fee. Also, plaintiff’s claim of substantive due process violation was without merit where: (1) plaintiff’s complaint did not implicate fundamental right; and (2) booking fee had rational basis, where fee served as offset of costs of booking arrestees. (Dissent filed.)