2019—“I dissent!,” exclaims Sixth Circuit judge Bernice Donald in Fowler v. Benson. The panel majority rejects a challenge to a Michigan law that requires that a person’s driver’s license be suspended when that person has failed to pay fines. But Donald opines that enforcement of that law against indigent drivers “without regard to their ability to pay and without affording them reasonable payment alternatives” violates their due process rights.