of some courts that have either applied the Excessive Fines Clause to challenged state action or assumed without deciding that the Clause applies. See, e.g., Hamilton v. City of New Albany, Indiana, 698 Fed.Appx. 821, 827-28, 2017 WL 2615453, at *5 (7th Cir. Jun. 16, 2017) (vacating summary judgment for city on plaintiffs federal excessive-fines claim and remanding for trial without mentioning incorporation or McDonald); Cripps v. Louisiana Dep’t of Agriculture and Forestry, 819 F.3d 221, 234 (5th Cir. 2016) (“Assuming arguendo that the Excessive Fines Clause applies, the record indicates that each of Plaintiffs’ offenses resulted in fines that do not exceed the limits prescribed by the statute authorizing it.”); Discount Inn, Inc. v. City of Chicago, 803 F.3d 317, 320 (7th Cir. 2015) (<HOLDING>); Public Employee Retirement Admin. Comm’n v.
holding that forfeitures may violate the eighth amendment excessive fines clause holding the eighth amendment succinctly prohibits excessive sanctions it provides excessive bail shall not be required nor excessive fines imposed nor cruel and unusual punishments inflicted  holding that excessive fines clause does not apply to civiljury award of punitive fines holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable holding that punitive damages are not fines