Gary Fields v. Henry County, Tennessee
2012 U.S. App. LEXIS 25159, 701 F. 3d 180, 2012 WL 6097334 (2012)
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Rule of Law:
A county's policies of using a bond schedule to set bail and automatically detaining domestic-assault arrestees for a temporary period do not violate the Eighth Amendment's Excessive Bail Clause or the Fourteenth Amendment's Due Process Clause, as the former governs the amount of bail, not its timing or process, and the latter is only implicated if state law creates a liberty interest through mandatory language guaranteeing a specific outcome.
Facts:
- On December 11, 2008, Gary Fields's wife contacted the Henry County Sheriff's office alleging that Fields had hit and choked her.
- Police observed that Mrs. Fields had a bloody lip, abrasions, and bruises.
- The next day, an officer obtained a warrant for Fields's arrest for misdemeanor domestic assault.
- Three days later, Fields learned of the warrant and turned himself in to the Henry County Sheriff's Office.
- During booking, Fields requested to post bail but was told he could not do so until the next day.
- A Sheriff informed Fields that, due to a county policy for all domestic violence arrests, he had to be detained for 12 hours before bail could be addressed.
- This county policy differed from Tennessee state law, which required a finding that the offender was a threat to the victim before imposing such a hold.
- Ten months after Fields was released on bail set by a judge the following morning, prosecutors dropped the domestic-assault charge against him.
Procedural Posture:
- Gary Fields filed a § 1983 lawsuit in federal district court against Henry County, alleging violations of his Eighth and Fourteenth Amendment rights.
- The district court granted Henry County's motion for summary judgment, ruling in favor of the county.
- Fields (appellant) appealed the district court's decision to the U.S. Court of Appeals for the Sixth Circuit, where Henry County was the appellee.
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Issue:
Do a county's policies of automatically detaining domestic assault arrestees for 12 hours and using a pre-set bond schedule to determine bail violate the Eighth Amendment's Excessive Bail Clause or the Fourteenth Amendment's Procedural Due Process Clause?
Opinions:
Majority - Amul R. Thapar
No, the county's policies do not violate the Eighth or Fourteenth Amendments. The Eighth Amendment's Excessive Bail Clause is not violated because it governs the amount of bail, not the process of setting it or the timing of release. Bond schedules are not inherently unconstitutional, and a violation only occurs if the scheduled amount is 'grossly disproportional to the gravity of a defendant’s offense,' which Fields did not argue. Furthermore, the 12-hour hold does not constitute a denial of bail, as there is no constitutional right to speedy bail. The Fourteenth Amendment's Due Process Clause is not violated because Fields cannot demonstrate a constitutionally protected liberty interest. For a state law to create such an interest, it must use mandatory language that dictates a specific substantive outcome. The Tennessee laws cited by Fields, which provide for hearings or require detention for dangerous individuals, are either procedural in nature or do not mandate a specific outcome like immediate release for individuals in his position. Therefore, without a protected liberty interest, the due process claim fails.
Analysis:
This decision reinforces a clear distinction between the procedural requirements of state law and the substantive protections of the U.S. Constitution in the context of bail. The court clarifies that the Eighth Amendment is concerned with the excessiveness of the bail amount itself, not the procedures or timing involved in setting it. Crucially, the ruling narrows the path for procedural due process claims based on state-created rights, affirming that only state laws with explicit, mandatory language guaranteeing a specific substantive outcome (like release) can create a federally protected liberty interest. This makes it more difficult for plaintiffs to succeed on § 1983 claims simply by pointing to a local government's failure to follow state procedural statutes.
