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143164P.pdf   05/04/2016  Erik Mickelson  v.  County of Ramsey
   U.S. Court of Appeals Case No:  14-3164
   U.S. District Court for the District of Minnesota - Minneapolis   
[PUBLISHED] [Gruender, Author, with Wollman and Bye, Circuit Judges] Civil Case - civil rights. Challenge to jail policy of deducting $25 booking fee from cash held by detainee upon booking does not violate procedural due process, as the private interest in deprivation of $25 was relatively modest and the county's interest in collecting fees at booking is substantial to ensure collection. The policy allows for corrections of any errors inherent in the overinclusive system of upfront collection and any placing of onus on detainee to seek refund is not so cumbersome as to undermine the constitutional adequacy of the post-deprivation refund process. The post-deprivation process remedy suffices to pass constitutional muster. Contention that any post-deprivation process was inadequate is rejected. Plaintiffs did not allege the system was inadequate. Judgment to defendants on the pleadings is affirmed. Use of prepaid debit-card scheme for refund of cash, minus booking fee, does not deprive procedural due process, as the use of a debit-card does not create a constitutionally cognizable interest to trigger due process protections, as distinction between cash and debit card is not constitutionally significant, noting fees were both avoidable and minor.