Robert Frazier v. Prince George's County, Maryland, 23-6359

Prince George’s County operates a three-step pretrial process: (1) magistrate initial appearance, (2) bail-review by a county judge, and (3) Pretrial Services review when a judge’s commitment order is made “subject to” Pretrial Services.
Judges sometimes commit detainees yet add a “condition” permitting Pretrial Services to consider release; Pretrial Services applies its own criteria and may take months without updating the detainee.
Former detainees sued under § 1983 and the Maryland Constitution, seeking a preliminary injunction to enjoin the County’s pretrial-release program as violative of Due Process.
After an eight-month delay, the district court denied the preliminary-injunction motion in a telephonic hearing and issued a brief written order denying relief “for the reasons stated on the record.”
The Fourth Circuit held the district court violated Fed. R. Civ. P. 52(a)(2) by failing to state the factual findings and legal conclusions supporting denial of the injunction, vacated the order, and remanded for further proceedings; it declined to resolve the merits given an insufficient record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court comply with Fed. R. Civ. P. 52(a)(2) when denying the preliminary injunction?	District court failed to state required factual findings and legal conclusions.	Denial was appropriate given factual gaps and lack of record.	Court: Violation of Rule 52(a)(2); remanded for findings.
Should the appellate court overlook a Rule 52(a)(2) error and decide the injunction on the merits?	Ask court to excuse the error and grant injunction based on record.	Urge affirmance / that remand is unnecessary.	Court: Declined to reach merits — record insufficient to decide.
Does a commitment order "subject to" Pretrial Services mean the judge authorized release (implicating due process)?	A judge’s inclusion of Pretrial Services as an option implicitly authorizes release, so post-order detention may violate due process.	The commitment reflects a state-law finding warranting detention; the "condition" merely allows Pretrial Services to apply its separate criteria.	Court: Key factual question disputed and unresolved; not decided on appeal.
Do plaintiffs have Article III standing to seek the injunction?	Detainees allege unconstitutional detention, causation by County, and redress via injunction.	County argued plaintiffs lacked standing.	Court: Standing challenge unsuccessful; plaintiffs have standing.

Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (sets four-factor standard for preliminary injunctions)
United States v. Salerno, 481 U.S. 739 (1987) (due process principles governing pretrial detention)
Mayo v. Lakeland Highlands Canning Co., 309 U.S. 310 (1940) (importance of compliance with Rule 52 in injunction rulings)
Kelley v. Everglades Drainage Dist., 319 U.S. 415 (1943) (scope of findings required under Rule 52)
Hoechst Diafoil Co. v. Nan Ya Plastics Corp., 174 F.3d 411 (4th Cir. 1999) (Rule 52’s role in informing parties and enabling appellate review)
Di Biase v. SPX Corp., 872 F.3d 224 (4th Cir. 2017) (standard of review for preliminary-injunction denials)
Westley v. Southern Ry. Co., 250 F.2d 188 (4th Cir. 1957) (appellate discretion to overlook Rule 52 error only when record permits)
Anderson v. Bessemer City, 470 U.S. 564 (1985) (appellate courts must not supplant district court factfinding)