Legal Memorandum: Payment of a Fine and Admission of Guilt

Issue: Whether payment of a fine constitutes an admission of guilt that may not be challenged at an administrative hearing?

It appears that the voluntary payment of a fine constitutes an admission of guilt that eliminates the right to appeal the underlying violation.  “The question of a defendant’s rights where the sentence has already been executed by imprisonment or payment of the fine seems to be one of first impression here.  We hold that . . . where it appeared that the district court was convinced that the plea of each defendant and the payment of the fine were the voluntary acts of each individual and where it appeared that the sentence of the . . . court had already been executed by the payment of the fine, that the district court was right in dismissing the attempted appeals, because at the time the appeals were attempted there no longer existed any judgments from which appeals could be taken, since the cases wee ended and closed.”  Boulton v. Kwiatkoski, 40 N.W.2d 417 (Minn. 1949).

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