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dollars every day they use the service, and while “[a]n indigent offender may request lowered fees, or fees waived based on financial need,”16 there
for not paying a fine or fee before sentencing him to jail time.”); see also Williams v. Illinois, 399 U.S. 235, 244 n.20 (1970) (“What we have said
22143730, at *1 n.2 (D. Minn. Aug. 18, 2003) (same); Nichols v. Rysavy, 809 F.2d 1317, 1327 (8th Cir. 1987) (noting the litigants’ reliance on Supreme
Wuerth, supra note 26, at 353. 115. See Medellin v. Texas, 552 U.S. 491, 505 n.2 (2008) (“[A] ‘non-self-executing’ treaty does not by itself give rise
reasonable times and negotiating n good faith with respect to grievances, disciplinary disputes, and other terms and conditions of employment.”). New
192. Id. at 1982 n.1. 193. This is true notwithstanding Justice Kennedy’s assertion that the Court’s “special needs cases . . . do not have a direct
Nielson to its facts in Oxford Health Plans LLC v. Sutter, 133 S. Ct. 2064, 2069 (2013). 77. Stolt-Nielsen, 559 U.S. at 687 n.10 (“We have no
Caswell v. Licensing Comm’n, 444 N.E.2d 922, 925 (Mass. 1983) (“[N]o case has ever held or suggested that simple physical activity falls within the
Id. at 829 n.8. 95. Id. at 829-30. 96. In re Humboldt Creamery, L.L.C., No. 09-11078, 2009 WL 2820610, at *1 (Bankr. N.D. Cal. Aug. 14, 2009
§ 9, at 117 (2005) (“[N]o court has held that property is not a proper jurisdictional basis on which to bring an action to recognize or enforce a