Williams v. Illinois

Facts of the Case

At petitioner’s bench trial for rape, Sandra Lambatos, a forensic specialist at the Illinois State Police lab, testified that she matched a DNA profile produced by an outside laboratory, Cellmark, to a profile the state lab produced using a sample of petitioner’s blood. She testified that Cellmark was an accredited laboratory and that business records showed that vaginal swabs taken from the victim, L. J., were sent to Cellmark and returned. She offered no other statement for the purpose of identifying the sample used for Cellmark’s profile or establishing how Cellmark handled or tested the sample. Nor did she vouch for the accuracy of Cellmark’s profile. The defense moved to exclude, on


Is the Equal Protection Clause of the Fourteenth Amendment violated when an impoverished defendant is imprisoned to satisfy payment of a fine and court costs?


Justice John M. Harlan wrote a concurring opinion in which he argued that the Illinois law was impermissible under the Due Process Clause of the Fourteenth Amendment rather than the Equal Protection Clause because the latter ruling would place a substantial burden on states to create a system of individualized fines. Additionally, the Equal Protection clause allowed judges to substitute their opinions for those of the legislature, while the Due Process Clause placed legislation that deprives an individual of his right to remain free under higher judicial scrutiny. Justice Harlan determined that the state interests in forcing someone without assets to “work off” their fines as opposed to using a payment plan or other alternative are administrative convenience and better crime deterrence, but that these interests cannot justify depriving poor individuals of their liberty.

Case Information

  • Citation: 399 US 235 (1970)
  • Argued: Apr 22, 1970
  • Decided Jun 29, 1970