Timbs v. Indiana
The United States Supreme Court held that the Eighth Amendment's Excessive Fines Clause applied to the individual states. Timbs pled guilty in an Indiana state court to dealing in a controlled substance and conspiracy to commit theft. When he was arrested the police seized Timbs's $42,000 vehicle which he had purchased with insurance money from when his father passed away. Subsequently, the state sought civil forfeiture of the vehicle, noting that the maximum fine that could be imposed upon him for his conviction was $10,000. The state trial court held that the forfeiture was disproportionate to the maximum fine allowed and the Indiiana Court of Appeals affirmed. The Indiana Supreme Court, however, reversed and held that the Eighth Amendment's Excessive Fines Clause only applied to federal actions, not state actions.
Timbs appealed and the United States Supreme Court held that the Fourteenth Amendment's Due Process Clause incorproated and rendered applicable the Bill of Rights to the individual states. The Court provided a historical anaylsis of the origins o the Excessive Fines Clause, originating from the Magna Carta. The Court, therefore, vacated and remanded the opinion of the Supreme Court of Indiana.