Filed Date: Oct. 21, 2015
Closed Date: 2016
Clearinghouse coding complete
On October 21, 2015, an arrestee filed this class action lawsuit in the U.S. District Court for the District of Kansas. The plaintiff sued Dodge City and Ford County under 42 U.S.C. § 1983. The plaintiff alleged that the Dodge City's wealth-based post-arrest detention scheme violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The plaintiff sought injunctive relief, compensatory damages, and a declaratory judgment that the City's wealth-based detention practices were unlawful.
The plaintiff, a Native American citizen of Dodge City, was arrested and held at the Ford County Jail because he could not pay $250 to the City of Dodge City. In Dodge City, arrestees faced two different outcomes depending on their wealth status: Wealthy arrestees paid an amount set by the bail schedule and were not held in jail, while poor arrestees were put in jail for 48 hours because they could not afford to pay the City's pre-determined bail for their offense. Bail amounts ranged from $250-$2500. Under the City's scheme, the sole criterion for determining whether a pretrial arrestee walked free or sat in jail was the amount of money that he had. The plaintiff alleged that this policy and practice of using a fixed "bail schedule" to determine the amount of money necessary to secure post-arrest release and the practice of requiring cash up-front to avoid post-arrest detention violated the Fourteenth Amendment's Due Process and Equal Protection Clauses.
The plaintiff sought to certify a class on behalf of himself and all other arrestees unable to pay for their release pursuant to Dodge City's fixed bail schedule who were, are, or who will become in the custody of Dodge City. On November 25, 2015 and on February 24, 2016, the court (Judge Teresa J. James) granted motions to stay all proceedings to allow the parties to explore a non-litigation resolution.
On April 22, 2016, the parties submitted a joint motion for entry of final declaratory and injunctive relief and joint stipulation of dismissal with prejudice. On April 26, 2016, the court (Judge Daniel D. Crabtree) issued a declaratory judgment, stating that persons cannot, consistently with the Equal Protection Clause, be held in custody after a non-warrant arrest because they are too poor to post a monetary bond. It also entered an injunction, ordering the release of individuals arrested for non-warrant arrests in Dodge City for violation of municipal ordinances on Own Recognizance Bonds without further conditions of release and without requiring posting any monetary bond. The court dismissed the plaintiff’s motion for class certification, motion for temporary restraining order and preliminary injunction, and remaining claims with prejudice. The court retained jurisdiction to enforce the injunction, but the case appears closed otherwise. 2016 WL 9051913.
Summary Authors
Rachel June-Graber (11/2/2015)
Julie Singer (2/27/2017)
Keagan Potts (3/19/2019)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/13322140/parties/martinez-v-city-of-dodge-city/
Crabtree, Daniel D (Missouri)
Antosh, Peter J. (Kansas)
Hubbard, Katherine (District of Columbia)
Crouse, Toby Jon (Kansas)
Henson, D. Keith (Missouri)
See docket on RECAP: https://www.courtlistener.com/docket/13322140/martinez-v-city-of-dodge-city/
Last updated April 21, 2025, 10:15 a.m.
State / Territory: Kansas
Case Type(s):
Special Collection(s):
Fines/Fees/Bail Reform (Criminalization of Poverty)
Key Dates
Filing Date: Oct. 21, 2015
Closing Date: 2016
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
The plaintiff is a private citizen of Dodge City, Kansas.
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Denied
Defendants
City of Dodge City (Dodge City, Ford), State
Defendant Type(s):
Case Details
Causes of Action:
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Content of Injunction:
Preliminary relief request withdrawn/mooted
Order Duration: 2016 - None
Issues
General/Misc.:
Jails, Prisons, Detention Centers, and Other Institutions: