Several court decisions, including Bearden v. Georgia (1983) and Doe v. Angelina County, Texas (1990) provide definitive guidance on the requirement for postconviction hearings as a predicate to lawful conversion of fine-only judgments into jail sentences. The position is that government has a responsibility as a matter of due process to re-examine the possibility of ongoing indigency within the environment of a fine only case. Although Doe v. Angelina County offers the most complete analysis and guidance for fine only cases on the relationship between equal protection and procedural due process, it falls short in helping lower courts in the equally important additional inquiry into substantive due process. A fundamental question remains concerning the rationale by which a judge may convert a fine into a jail sentence for persons who have made bonafide efforts to pay and/or who lack the ability to fulfill alternative sentences. Aside from the general requirement of Doe v. Angelina County that some form of due process hearing is required for the review of a fine in default within lower courts, it must be additionally recognized that both the format for a hearing and its record are important. Cases decided by the lower court system and the U.S. Supreme Court are analyzed in terms of due process and equal protection issues. 51 footnotes