on transfer of wealth was implemented to burster truants financial coppers found various city wide departments and to supplement its tax base how did this happen how did ms williams become or to appear or so to pay something from a legitimate conviction does not make the following convictions legitimate but that's really not of any consequence here because what we're talking about as a policy we're not talking about the nuts and bolts of each of those convictions we're talking about the policy of the city the official policy which many believe starts at the top with the mayor and the city council and then spreads down to  this case would not invalidate the original for our convictions it would mean validate anything at all really what it does is it clunks out and that the policy that was used by the state or by the city in this case w new criminal charges based on those warrants they're actually just a violation the previous court order to pay fines so they're more in the nature of conviction proceedings and this case didn't they actually file new charges and if they filed new their right to counsel before they can actually see the judge when they see the judge the judge makes no inquiry and has absolute immunity is not a bar even under the ordinance he was discharged the duty to make conceivable and this is the type of thing that we would probably learned through discovery but it's conceivable that the judge was working in cahoots with the city and the judge was acquiescing to the city's demands on what or what not to do in the courtroom i mean this is not a summary other claims that are barred so the way i'm coming at this is that we have to look at each of the claims i believe term and whether it's i don't think it's robert down on iraq in other words i think each claim has to be examined individual lead to variety of levels from the person who is stapling the summonses together all the way up to the mayor and i agree joe johns i agree with your point is one i kind of clumsily tried to make before it's the lack of all those required to show and we think that we allege this is a i'm a policymaker we have the mayor in the city council we attached exhibits which reflect that autonomy in meeting in furthering the policy  implicated if there could be a willful failure to pay or for example there was a finding that the defendant was not indigent doesn't that take at least that particular claim out of the actions those judicial actions are attributable to this so the judge not the city and as far as the part found a policymaker the judge cannot be the final policy maker for the city because the judge's decision is not the final say the circuit is and this context when they're taking judicial actions there's no way he can be a ploy the city of sure would because they simply have no control over him and it's a car versus cash so even the evans case which is about whether or not the clerk and the judge did no allegation of the city issued ones that were unlawful which by the waiter's no there's no claim that any warrant was actually invalid there's just no role the city could play in any of this aside from the allegation that we set up that we unconstitutional it can't just be a policy or ordinance decision allow something to happen everything could allow something that happened it has to be required it has to direct it and there's no allegation here that anything happened or any state anything that would  a constitutional violation now i want to quickly go to the such limitations as well this case is all about the imprisonment she said in a complaint this about multiple convictions resulting in one hundred and sixty days of incarceration she went into jail or she got out of jail in jet bars the planets claim really quickly a fancy i made this or i made this point and the brief but i we looked at the fan complaint fan had sixty one allegations against city jail staff doing things there's talks about these convictions and there's a failure to pay the city jail will take in the person as alleged the complaint and say you're not getting out and show you pay the money and they would keep them there until the criminal defendant paid the money judicial act the statue of limitations applies and i believe i believe hec applies to all these because i think this would necessarily invalidate the convictions for failure to pay a fine and invalidate the sentences that the judge handed down provided by those  it's like we're talking two different languages we have the defendant who is myopically looking him straight through this microscope intentionally disregarding the bigger picture here  don't on ledge that the judge in this case was a policy maker or a final policy maker we allege that the city council the city of sure would through the city council and to the mayor are the final policy makers of this the pendants argument is custom that starts from the top and that's what judge hailed that in this case as well as his clerks as well as the people who run the jail as well as well as the as the court officials the police officers the people who showed up at random times on christmas eve at this woman's