from imprisonment — from government custody, detention, or other forms of physical restraint — lies at the heart of the liberty that Clause protects.... The civil confinement here at issue is not limited, but potentially permanent. Zadvydas, 533 U.S. at 690-91, 121 S.Ct. 2491 (citations omitted). The Court continued that “[a] statute permitting indefinite detention of an alien would raise a serious constitutional problem.” Id. at 690, 121 S.Ct. 2491. Following this rationale, no less of a problem arises if indefinite detention were caused by the inability to pay a bond. Indeed, the language of Zadvydas compels the conclusion that the bond must be low enough that the immigrant is able to meet it. See also Williams v. Illinois, 399 U.S. 235, 243, 90 S.Ct. 2018, 26 L.Ed.2d 586 (1970) (<HOLDING>). “[T]he alien’s release [post-removal-order]
holding that forfeiture of 357144 in currency was excessive where the maximum statutory fine was 250000 and the maximum fine under the sentencing guidelines was 5000 holding that state may not revoke probation for nonpayment of fine where probationer is unable to pay through no fault of his own holding that state may not imprison indigent defendant solely for inability to pay fine holding that state may not subject indigent defendants to period of imprisonment beyond statutory maximum holding in a case where the maximum time of imprisonment was extended because an indigent defendant was unable to pay a fine and court costs that a state may not constitutionally imprison beyond the maximum duration fixed by statute a defendant who is financially unable to pay a fine