Michael Platt v. Dorothy Brown, 872 F.3d 848

Illinois law allowed pretrial release via personal recognizance, full-deposit bail, or a 10% bail bond where the State retained 1% of the total bail (a 10% deposit with 1%—the “Bail Bond Fee”—kept by the State).
Michael Platt posted a 10% bond on $2,000,000 bail in 2014; after acquittal he received $180,000 back because $20,000 (1% of $2,000,000) was retained as the Bail Bond Fee.
In 2015 the Illinois legislature amended the statute to cap the Fee at $100 in counties with population over 3,000,000, effective January 1, 2016.
Platt sued on behalf of a putative class seeking recovery of Fees over $100 paid in the five years prior to the cap, alleging violations of federal and Illinois due process and equal protection, the Illinois uniformity clause, and unjust enrichment.
Defendants (Cook County Clerk and Treasurer, in their official capacities) moved to dismiss for failure to state a claim; the district court granted the motion and the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural due process	The Fee deprived Platt of property without adequate process because it was retained by the State.	Fee is ministerial and automatic; no amount of process would change the constitutional validity of the percentage charged.	Dismissed — no procedural due process violation.
Federal equal protection	Fee is irrationally disparate because some defendants pay much less than Platt did.	All who use the 10% system are charged the same 1% — variation is disparate impact, not disparate treatment.	Dismissed — no equal protection violation.
Illinois uniformity / state equal protection	Fee violates Illinois uniformity clause by producing unequal results across defendants.	Everyone in the 10% bond class is treated alike; classification is not arbitrary.	Dismissed — uniformity and state equal protection claims fail.
Substantive due process	The 1% Fee (as applied) bears no rational relation to the cost of processing bonds and is arbitrary.	Fee need only be rationally related to legitimate interests (encouraging full-deposit bonds, administrability, defraying costs/losses).	Dismissed — rational basis satisfied; substantive due process claim fails.
Unjust enrichment	Collecting unconstitutional Fees unjustly enriched defendants.	Unjust enrichment claim depends on constitutional invalidity; if Fee valid, claim fails.	Dismissed — tied to failed constitutional claims, so it fails.

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard for Rule 12(b)(6))
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards; plausibility and inferences)
Smith v. Boyle, 144 F.3d 1060 (disparate impact is not an equal protection violation)
Schilb v. Kuebel, 404 U.S. 357 (characterizing bail-bond fee as administrative, not a fundamental right)
Markadonatos v. Village of Woodridge, 760 F.3d 545 (fee constitutionality does not require exact equality with cost)
FCC v. Beach Communications, Inc., 508 U.S. 307 (rational-basis review allows hypothetical justifications)
Cleary v. Philip Morris Inc., 656 F.3d 511 (unjust enrichment claim rises or falls with related claims)