Grashoff v. Adams

Dist. Ct. did not err in granting defendant’s motion for summary judgment in plaintiff's section 1983 action, alleging that defendant violated Eighth Amendment’s Excessive Fines Clause, when defendant assessed plaintiff forfeiture and penalty totaling $11,190, which represented all unemployment benefits that plaintiff had received during 24-week period, plus 25 percent penalty, after defendant found that plaintiff had failed to report during same 24-week period fact that she had received income from part-time job that would have reduced her weekly unemployment benefit, as she was required to do under Indiana statute. Record showed that: (1) plaintiff received $8,952 during instant 24-week period, when she should have only received $6,123.25 had she properly reported her part-time income; (2) plaintiff made 24 weekly false statements indicating that she had not made any income during same 24-week period; and (3) defendant notified plaintiff that she was required to repay all of her $8,952 in benefits because of her false statements, as required under Indiana statute and tacked on $2,238 penalty, as allowed under Indiana statute. Eighth Amendment Excessive Fines Clause applies only to “punitive” as opposed to “remedial” fines, and record showed that $2,238 penalty, as well as only amount that plaintiff could have received had she been honest, i.e., $6,123, potentially qualified as being covered under Excessive Fines Clause. However, no Excessive Fines Clause violation occurred, where total amount of sanction under Eight Amendment scrutiny is not grossly disproportionate to plaintiff’s 24 separate false statements that attempted to hide her part-time income that would have reduced her weekly unemployment benefit.