Sentinel Offender Services, LLC v. Glover, 296 Ga. 315

Thirteen civil actions were filed against Sentinel Offender Services and others challenging private probation in Georgia courts.
Plaintiffs alleged unconstitutional private probation framework, improper tolling of misdemeanor sentences, and unauthorized fees/electronic monitoring.
Columbia County cases questioned a Sentinel contract not approved by the county governing authority under OCGA § 42-8-100(g)(1).
Richmond County cases challenged contracted private probation, excessive fees, and certain sentencings and monitoring practices.
Trial court consolidated issues, held OCGA § 42-8-100(g)(1) constitutional, prohibited tolling, and restricted certain monitoring/fee practices; granted injunctive relief and partial summary judgment.
This Court affirmed in part, reversed in part, and remanded for further proceedings on justiciability, class certification, and injunctive relief consistency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of OCGA § 42-8-100(g)(1)	Glover argues statute is facially invalid and deprives due process/equal protection.	Sentinel argues statute is facially valid and within legislative authority.	Statute not unconstitutional on its face.
Authority to toll misdemeanor sentences under private probation	Tolling is permissible under private probation; limits on tolling are unconstitutional.	Tolling not authorized for misdemeanor probation under private framework.	Tolling of misdemeanor sentences not permitted.
Imposition of electronic monitoring in private probation	Electronic monitoring cannot be imposed without statutory authorization for misdemeanor probationers.	Judges may impose reasonable probation conditions, including electronic monitoring, under general authority.	Electronic monitoring may be imposed; not barred by statute.
Money had and received for unauthorized probation fees	Sentinel wrongfully collected fees; plaintiffs entitled to restitution.	Fees were authorized by sentencing orders or court authority; no recovery.	Recovery allowed for fees collected under invalid/unauthorized contracts; impact varies by county.
Class certification and injunctive relief on remand	Broad class certification appropriate for fees and practices.	Class boundaries/relief need careful tailoring; issues unsettled on record.	Conditional class certifications reversed; remand for reconsideration under this opinion; injunctive relief reconsidered.

Owens v. Hill, 295 Ga. 302 (Ga. 2014) (collateral relief when direct appeal not available)
Bearden v. Georgia, 461 U.S. 660 (U.S. 1983) (due process in Bearden context; probation/ability to pay)
Johnson v. State, 307 Ga. App. 570 (Ga. App. 2011) (Bearden principles; probation conditions)
Connally v. State, 265 Ga. 563 (Ga. 1995) (imprisonment for debt vs. criminal conduct)
Ballenger v. State, 210 Ga. App. 627 (Ga. App. 1993) (probation conditions must be reasonable)
McMahon v. State, 284 Ga. App. 192 (Ga. App. 2007) (Bearden-like considerations in probation context)
Haugabook v. Crisler, 297 Ga. App. 428 (Ga. App. 2009) (money had and received principle)