Maurice Walker v. City of Calhoun, GA
682 F. App'x 721
11th Cir.2017Background
- Maurice Walker was arrested by the City of Calhoun for a misdemeanor (pedestrian under the influence) and was told he must pay a $160 cash bond under the municipal court’s standing bail schedule for immediate release.
- Indigent arrestees who could not pay the preset cash amount were detained until the municipal court’s next session (usually Monday) for a first appearance at which release on recognizance might be available.
- Walker, detained because he could not afford the bond, sued the City alleging the bail policy violated equal protection and due process by conditioning release solely on ability to pay and not providing non-monetary alternatives.
- Walker moved for a preliminary injunction to prohibit the City from jailing indigent misdemeanor arrestees without offering unsecured bonds or release on recognizance; the district court granted the injunction without a hearing.
- The Eleventh Circuit reviewed the preliminary injunction for abuse of discretion and focused its decision on whether the district court’s injunction complied with Federal Rule of Civil Procedure 65’s specificity requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court's injunction complied with Fed. R. Civ. P. 65(d) specificity requirements | Walker argued the injunction was necessary to stop unconstitutional detention of indigent arrestees and ordered release on unsecured bonds/recognizance | City argued the injunction was overbroad/unclear and that procedural requirements needed clearer standards | The injunction violated Rule 65: it was an unenforceable "obey the law" command and lacked an operative, specific command enforceable or reviewable; vacated and remanded |
| Whether ordering the City to implement constitutionally compliant post-arrest procedures was sufficiently specific | Walker contended the City must be required to adopt procedures that avoid incarcerating indigent misdemeanor arrestees solely for inability to pay | City contended the district court’s order gave no guidance on what constitutionally adequate procedures entail and risked contempt for future, unrelated conduct | Court held the mandate to "comply with the Constitution" and to devise procedures was too vague; injunction must specify concrete, enforceable commands |
Key Cases Cited
- United States v. Alabama, 691 F.3d 1269 (11th Cir. 2012) (standard of review for preliminary injunction decisions)
- Scott v. Roberts, 612 F.3d 1279 (11th Cir. 2010) (review standards for factual findings and legal conclusions)
- GeorgiaCarry.Org, Inc. v. U.S. Army Corps of Engineers, 788 F.3d 1318 (11th Cir. 2015) (elements required for a preliminary injunction)
- Hughey v. JMS Dev. Corp., 78 F.3d 1523 (11th Cir. 1996) (Rule 65 requires specificity to inform enjoined parties and permit appellate review)
- Louis W. Epstein Family P’ship v. Kmart Corp., 13 F.3d 762 (3d Cir. 1994) (broad, non-specific injunction language is improper)
- Int’l Longshoremen’s Ass’n v. Philadelphia Marine Trade Ass’n, 389 U.S. 64 (U.S. 1967) (invalidating an injunction that merely ordered compliance with another instrument)
- Russell C. House Transfer & Storage Co. v. United States, 189 F.2d 349 (5th Cir. 1951) (courts should not enjoin in general terms that expose parties to contempt for future unrelated acts)
Disposition: The Eleventh Circuit vacated the preliminary injunction for lack of Rule 65 specificity and remanded for further proceedings consistent with the opinion.