Smith v. State of Missouri (In re Zachary A. Smith)
- Citation:
- No. 13-1769 (unpublished)
- Tag(s):
-
- Ruling:
- The Eighth Circuit Court of Appeals affirms the prior court rulings, denying contempt. It does so on three bases: (1) the Rooker-Feldman doctrine precludes consideration, (2) the Appellant prison's post-bankruptcy incarceration costs constitute post-petition obligations, not subject to discharge, and (3) the Missouri Incarceration Reimbursement Act does not violate the Supremacy Clause of the U.S. Constitution.
- Procedural context:
- After discharge was awarded and Chapter 7 case closed, State garnished wages going to prisoner Mr. Smith. Mr. Smith then moved for contempt against the state, citing recent state court opinion holding that Missouri Incarceration Reimbursement Act may only be enforced against assets to which an inmate has a present right. The bankruptcy court denied the motion for contempt. The Bankruptcy Appellate Panel affirmed the bankruptcy court decision, and the Eighth Court of Appeals now rules.
- Facts:
- Missouri has a state law, the Missouri Incarceration Reimbursement Act, which reimburses the State for the costs for housing prison inmates. Missouri in this case obtained a judgment for the costs of housing a prisoner, Mr. Smith, sentenced to life in prison. The judgment garnished any funds Mr. Smith earned, working in prison. Mr. Smith filed for Chapter 7 bankruptcy, and received a discharge. Thereafter, the prison continued to garnish Mr. Smith's wages. Mr. Smith moved for contempt against the State in his bankruptcy case.
- Judge(s):
- Loken, Bye, Benton
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