Christy Ann Martin v. John Fredrick Martin

A Mississippi chancery court held Petitioner in civil contempt and sentenced her to six months’ incarceration, suspended on payment, for failing to satisfy a $21,040.72 civil money judgment originating as a property-damages suit in county court. The court made no express finding as to Petitioner’s present ability to pay, placed the burden on Petitioner to disprove ability, and delegated to opposing counsel the authority to “automatically” trigger incarceration upon any missed installment. Two Justices of the Mississippi Supreme Court voted to grant certiorari. The questions presented are:

1. Whether the Due Process and Equal Protection Clauses of the Fourteenth Amendment, as applied in Bearden v. Georgia, 461 U.S. 660 (1983), and Turner v. Rogers, 564 U.S. 431 (2011), forbid a State from incarcerating an indigent judgment debtor for nonpayment of a private civil money judgment without a judicial inquiry into, and an express on-the-record finding of, present ability to pay.

2. Whether relabeling a civil money judgment as “contempt”—thereby exposing the debtor to imprisonment otherwise foreclosed by the constitutional prohibition on debtors’ prisons—violates the Fourteenth Amendment when ordinary civil-