A 36-year-old woman’s methamphetamine conviction has been tossed by a state appellate court because her arrest warrants were prematurely issued.
Jaclyn Rae Sleater was picked up in May 2014 because she had fallen behind on payments to Benton County Superior Court for legal financial obligations in two earlier felony drug cases.
The Benton County Clerk’s Office requested the warrants because Sleater had failed to schedule a hearing to explain why she had been neglecting those two accounts.
But the Washington state Court of Appeals says the responsibility should not be placed on a defendant to schedule their own hearing.
In this case, Sleater should have been sent a summons requiring her appearance before a judge at a set date and time to explain her failure to pay.
A judge first must determine the defendant’s “willfulness” to violate their payment obligations, the three-judge panel ruled. Then, an arrest warrant can be issued.
The appellate court agreed with Sleater’s argument “that the arrest warrants were invalidly issued without consideration of alternatives to arrest in violation of the Fourth Amendment to the United States Constitution.”
The Court of Appeals ruling came just weeks after a settlement was announced in a lawsuit against Benton County over the constitutionality of its longstanding practice of jailing people for unpaid fines and court costs.
The American Civil Liberties Union, or ACLU, has called the practice “a modern-day debtors’ prison.”
Under terms of the civil settlement, judges must ask about a person’s ability to pay at any hearing, and will not punish them if it is determined they lack the financial means.
Sleater reportedly had been entered into Benton County’s “pay or appear” program, and was making a combined monthly payment of $75 toward three previous cases.
Payments were being covered by a relative, who made a $150 online payment April 17, 2014, according to appellate documents. However, that payment was only applied to one case instead of divided into all three.
So, after noting that one account was behind four months and another seven months, the clerk’s office sought the warrants on April 22, 2014.
Sleater was arrested May 16, 2014. Court documents show that during booking at the jail, a corrections officer found a glass vile in Sleater’s undergarments.
She was charged four days later with possessing meth. Her defense lawyer was unsuccessful in getting the evidence suppressed, saying it was invalid because the warrants were wrongly issued.
Sleater opted not to have the case heard by a jury, and was convicted in February 2015 in a stipulated facts trial by Judge Alex Ekstrom. She was sentenced to nine months in county jail, with the work release alternative if eligible.
The Court of Appeals said the case never should have made it to that point because a judge erred in denying the motion to suppress.
Sleater’s case shows the importance of holding a hearing to inquire about the defendant’s ability to pay before issuing a warrant, the opinion said.
A judge would have found out that her relative’s recent payment was intended to be spread across all three accounts, and the court could have resolved the problem without needing to arrest Sleater, the appeals judges said.