institution that is a MasterCard principal member and asking for a cash advance for the balance on the card.” If the inmate instead converts the debit card back into cash using an ATM, only a onetime ATM fee of $2.75 automatically applies. Such a minimal imposition does not trigger constitutional due process protection. The D.C. Circuit explained almost thirty years ago that “matters involving a few dollars or less” do not trigger due process. Gray Panthers v. Schweiker, 652 F.2d 146, 156 n. 19 (D.C.Cir.1980). Several other courts have issued consistent decisions. See, e.g., Moncla v. Kelley, 430 Fed.Appx. 714, 718 (10th Cir.2011) (unpublished) (finding de minimis any lost interest on $20 that had been temporarily withheld); Kennedy v. City of Cincinnati, 595 F.3d 327 (6th Cir.2010) (<HOLDING>); Northern v. Nelson, 448 F.2d 1266, 1267 (9th
holding that plaintiffs may have a property interest in real property holding that an individuals property interest in a 10 pool pass was de minimis holding that scope of property subject to forfeiture is defined by the instrument creating an interest in the property holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit holding that even if an agreement that title would pass once financing was obtained the most a creditor could claim was a security interest once the good was delivered