Gary Fields v. Henry County, Tennessee
2012 U.S. App. LEXIS 25159
6th Cir.2012Background
- Henry County maintains a policy to detain domestic-violence arrestees for 12 hours irrespective of individual danger findings.
- Henry County also uses a bond schedule to set bail amounts for domestic-violence charges.
- Gary Fields was arrested for misdemeanor domestic assault; he was detained 12 hours and then bail was set by a judge the following day.
- Fields challenged the policy under §1983, claiming Eighth Amendment excessive bail and Fourteenth Amendment due process violations.
- The district court granted summary judgment for Henry County; on appeal, the court affirmed the district court’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether bond schedules violate the Eighth Amendment excess bail standard | Fields asserts bond schedule amounts can be grossly disproportionate | Henry County argues schedules are a normal, constitutional mechanism | No inherent constitutional problem with bond schedules; not excessive bail here |
| Whether the 12-hour hold constitutes an Eighth Amendment violation | Fields argues the hold denies prompt bail | Hold timing is not governed by Eighth Amendment | No Eighth Amendment violation; timing of bail not protected as such |
| Whether Fields has a protected liberty interest under due process theories | State-law rights create liberty interests demanding process | No state-law liberty interest to release earlier than determined | Tennessee bail laws do not create a protected liberty interest sufficient for due process claim |
Key Cases Cited
- Pugh v. Rainwater, 572 F.2d 1053 (5th Cir. 1978) (bond schedule serves speedy release; not inherently unconstitutional)
- Stack v. Boyle, 342 U.S. 1 (1951) (bail must be based on preserving appearance; factors vary by case)
- Bajakajian v. United States, 524 U.S. 321 (1998) (excessive bail must be grossly disproportional to gravity of offense)
- United States v. Salerno, 481 U.S. 739 (1987) (role of bail in the government’s purpose for pretrial detention)
- Wagenmann v. Adams, 829 F.2d 196 (1st Cir. 1987) (bond amount decisions faced scrutiny when aiming to guarantee confinement)
- Galen v. County of Los Angeles, 477 F.3d 652 (9th Cir. 2007) (right to bail procedures not automatically create liberty interests)