(2001)

Dear Sheriff Richard J. Voorhaar

In your capacity as warden of the St. Mary's County Detention Facility, you have requested our opinion as to the constitutionality of continued commitment of an inmate who has completed the specified period of incarceration but failed to pay a fine, when the sentence appears to make payment of the fine a condition of the inmate's release from custody.

State law provides that a court may sentence a convicted defendant who has failed to pay a fine to an additional period of confinement to "work off" the fine. However, under both State law and the federal…