Leticia Roberts v. Tony Thompson

── Leticia Roberts v. Tony Thompson ── Court: Court of Appeals for the Eighth Circuit Date: May 20, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1475 ___________________________ Leticia Roberts; Calvin Sayers Plaintiffs - Appellants v. Tony Thompson, in his official capacity as Black Hawk County Sheriff; Black Hawk County Defendants - Appellees ------------------------------ Cato Institute; Institute for Justice; Law School Clinics and Clinical Professors; NAACP Iowa-Nebraska State Area Conference of Branches Amici on Behalf of Appellant(s) ____________ Appeal from United States District Court for the Northern District of Iowa - Eastern ____________ Submitted: January 15, 2026 Filed: May 20, 2026 ____________ Before LOKEN, GRUENDER, and GRASZ, Circuit Judges. ____________ GRUENDER, Circuit Judge. Black Hawk County, Iowa charges its jail inmates fees for booking, room, and board (“jail fees”). The County Sheriff’s Office operates the jail and obtains confessions of judgment as part of its fee collection process. Leticia Roberts and Calvin Sayers, two former inmates of the jail, filed a 42 U.S.C. § 1983 action against Black Hawk County and County Sheriff Tony Thompson (collectively, “the County”). Roberts and Sayers contend that the County’s use of confessions of judgment violates their Fourteenth Amendment due process rights. The district court granted the County’s motion to dismiss for lack of standing and failure to state a claim. We vacate and remand for further proceedings. I. Background “In this appeal from the grant of a motion to dismiss, we accept as true the well-pleaded allegations in the amended complaint.” Kelly v. City of Omaha, 813 F.3d 1070, 1074 (8th Cir. 2016). Black Hawk County charges jail inmates seventy dollars per day of incarceration plus a twenty-five-dollar booking fee. Ordinarily, if a released inmate does not pay voluntarily, a county would need to collect unpaid fees by filing a civil reimbursement claim (the “civil reimbursement process”). See Iowa Code § 356.7(1). The civil reimbursement process requires review by an Iowa court, which can decide the claim on the merits. Iowa Code § 356.7(3); State v. Abrahamson, 696 N.W.2d 589, 593 (Iowa 2005). Instead of using the civil reimbursement process, the County has instituted a written policy compelling inmates to sign a confession of judgment at the time of their release. The County’s confession of judgment form indicates the amount of jail fees owed as the “balance due.” Jail officials seize any money on the person of an inmate or in his commissary account and list that on the form as the “amount -2- paid.”1 By signing the form, the inmate “hereby swear[s] on oath . . . that [he] owe[s] the [remaining] sums of money as indicated above, and that [he] confess[es] judgment in the amount of the above balance due.” Further, an inmate swears that he “understand[s] that if judgment is entered against [him], on this confession, [he] will further be liable for service of process fees and other court costs incurred in association with that judgment.” The County requires inmates to make minimum payments of twenty-five dollars per month towards their jail-fee debt. This monthly payment amount is listed on the confession. The County can file each confession of judgment with the clerk of the Iowa district court. See Iowa Code §§ 676.1, 6