Case: Bell v. City of Jackson

Bell v. City of Jackson, Mississippi

Bell v. The City of Jackson

U.S. Department of Justice

CLASS ACTION COMPLAINT against The City of Jackson, Mississippi ( Filing fee $ 400 receipt number 34643035775) filed by James Sheppard, Jerome Bell, Marteze Harris, Jarmale Walker, Ricky Lambert, Michael Davis, and Domonic Butler. (Attachments: # 1 Exhibit A - Bell, Mittimus 7/10/15, # 2 Exhibit B - Sheppard, Mittimus 9/4/15, # 3 Exhibit C - Harris, Mittimus 7/23/15, # 4 Exhibit D - Public Service Work Agreement, 9/15/15, # 5 Exhibit E - Butler, Mittimus 7/22/15, # 6 Exhibit F - Davis, Mittimus 4/13/15, # 7 Exhibit G - Lambert, Mittimus 8/14/15, # 8 Exhibit H - Public Service Work Agreement, 9/17/15, # 9 Exhibit I - Walker, Mittimus 7/13/15, # 10 Civil Cover Sheet)(ND) (Entered: 10/09/2015)

1 Exhibit A - Bell, Mittimus 7/10/15

View on PACER

2 Exhibit B - Sheppard, Mittimus 9/4/15

View on PACER

3 Exhibit C - Harris, Mittimus 7/23/15

View on PACER

4 Exhibit D - Public Service Work Agreement, 9/15/15

View on PACER

5 Exhibit E - Butler, Mittimus 7/22/15

View on PACER

6 Exhibit F - Davis, Mittimus 4/13/15

View on PACER

7 Exhibit G - Lambert, Mittimus 8/14/15

View on PACER

8 Exhibit H - Public Service Work Agreement, 9/17/15

View on PACER

9 Exhibit I - Walker, Mittimus 7/13/15

View on PACER

10 Civil Cover Sheet

View on PACER

Summons Issued as to The City of Jackson, Mississippi. (ND) (Entered: 10/09/2015)

SUMMONS Returned Executed by James Sheppard, Jerome Bell, Marteze Harris, Jarmale Walker, Ricky Lambert, Michael Davis, Domonic Butler The City of Jackson, Mississippi served on 10/14/2015, answer due 11/4/2015. (Johnson, J.) (Entered: 10/14/2015)

MOTION for Alec Karakatsanis to Appear Pro Hac Vice by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Attachments: # 1 Appendix Certificate of Good Standing)(Johnson, J.) (Entered: 10/16/2015)

1 Appendix Certificate of Good Standing

View on PACER

Pro Hac Vice fee paid for Alec Karakatsanis receipt number 0538-3051190 $ 100 (Johnson, J.)

Amended MOTION for Alec Karakatsanis to Appear Pro Hac Vice by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Attachments: # 1 Appendix Certificate of Good Standing)(Johnson, J.) (Entered: 10/19/2015)

1 Appendix Certificate of Good Standing

View on PACER

ORDER granting 5 Amended Motion to Appear Pro Hac Vice. Alec Karakatsanis shall be admitted pro hac vice to serve as co-counsel for the defendants Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard and Jarmale Walker. Signed by Magistrate Judge Robert H. Walker on October 19, 2015. (Joffe, Scherry) (Entered: 10/19/2015)

TEXT ONLY ORDER finding as moot 4 Motion to Appear Pro Hac Vice. Movants filed an Amended Motion 5 which the Court has granted by order 6 entered this date. NO FURTHER WRITTEN ORDER WILL ISSUE. Signed by Magistrate Judge Robert H. Walker on October 19, 2015. (Joffe, Scherry)

ANSWER to 1 Complaint,, by The City of Jackson, Mississippi.(Jackson-Winters, LaShundra) (Entered: 10/23/2015)

NOTICE of Hearing: Telephone Conference set for 11/5/2015 10:00 AM before Magistrate Judge Robert H. Walker to establish deadlines for class action discovery and to file a motion to certify a class. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephone Conference held on 11/5/2015 with attorneys J. Cliff Johnson and LaShundra B. Jackson-Winters who advised they are attempting to settle the case and are requesting additional time to continue settlement negotiations. The Court will not schedule deadlines at this time but will notice another telephonic status call for December 3, 2015 at 10:00 AM. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 12/3/2015 10:00 AM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 12/3/2015 with attorneys J. Cliff Johnson and LaShundra B. Jackson-Winters who advised they have participated in numerous lengthy in-person negotiations and advised they are making substantial progress toward settlement of the case, but are requesting additional time to continue the negotiations. The Court will notice another telephonic status call for January 5, 2016 at 1:30 PM. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 1/5/2016 01:30 PM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 1/5/2016 with attorneys J. Cliff Johnson and LaShundra B. Jackson-Winters who advised they continue to make substantial progress toward settlement of the case but are requesting additional time to continue negotiations. The Court advised it will allow one last opportunity to reach a settlement and will notice a telephonic status conference for February 16, 2016 at 10:00 AM. If the case has not settled by that date deadlines for class action discovery and to file a motion to certify a class will be scheduled. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 2/16/2016 10:00 AM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 2/16/2016 with attorneys J. Cliff Johnson, Gail W. Lowery and LaShundra B. Jackson-Winters. Counsel continue to negotiate settlement of the case in good faith and advised they have resolved all but four to five issues. The Court is directing that counsel meet in person in an attempt to finalize settlement and will schedule a telephonic status conference for March 2, 2016 at 10:00 AM. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 3/2/2016 10:00 AM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Reset Hearings: Telephonic Status Conference RESET for 3/2/2016 01:30 PM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Reset Hearings: Telephonic Status Conference RESET for 3/16/2016 01:30 PM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 3/16/2016 with attorneys J. Cliff Johnson, Gail W. Lowery and LaShundra B. Jackson-Winters who advised they continue in their efforts to resolve all issues but several remain contested. The Court directed the attorneys to continue in their attempts to settle the case but stated that the case will now proceed and that a telephonic case management conference will be noticed for April 28, 2016 at 1:30 PM. (SR)

Rule 16(a) Initial Order Telephonic Case Management Conference set for 4/28/2016 01:30 PM before Magistrate Judge Robert H. Walker. (SR) (Entered: 03/16/2016)

NOTICE of Appearance by Gail Wright Lowery on behalf of The City of Jackson, Mississippi (Lowery, Gail) (Entered: 04/07/2016)

NOTICE of Service of City of Jackson's Initial Disclosure by The City of Jackson, Mississippi (Jackson-Winters, LaShundra) (Entered: 04/21/2016)

NOTICE of Service of Initial Disclosure by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Johnson, J.) (Entered: 04/22/2016)

DOCKET ANNOTATION as to # 11 . This document is not accompanied by a certificate of service. A certificate of service must be attached to a document [Administrative Procedures for Electronic Case Filing, Sec. 4.A.1, Sec. 4.B, and Fed.R.Civ.P. Rule 5(d)(1)]. Attorney is directed to file a certificate as CERTIFICATE OF SERVICE and link it to the proper document. (ND)

ATTACHMENT re 11 Notice of Service of Disclosure - Certificate of Service by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Johnson, J.) (Entered: 04/25/2016)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Case Management Conference held on 4/28/2016 with attorneys J. Cliff Johnson, LaShundra B. Jackson-Winters and Gail Wright Lowery who advised that the attorneys have agreed to terms of a potential settlement of the case which is to be presented to the Jackson city council for consideration and approval at their next meeting on May 3, 2016. The Court will not enter a scheduling order at this time but will notice another telephonic status conference for May 5, 2016 at 10:30 AM. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 5/5/2016 10:30 AM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 5/5/2016 with attorneys Jacob W. Howard, LaShundra B. Jackson-Winters and Gail Wright Lowery. Counsel for the City of Jackson, Mississippi advised that the proposed settlement agreement was presented to the Jackson city council for approval at their meeting on May 3, 2016 and that the settlement was approved in principle. The attorneys are preparing a revised settlement agreement and will submit same to the Jackson city council for final approval at their June 7, 2016 meeting. The Court will notice a telephonic status call for June 9, 2016 at 3:00 PM. (SR)

NOTICE of Hearing: Telephonic Status Conference set for 6/9/2016 03:00 PM before Magistrate Judge Robert H. Walker. Plaintiff will place the telephone call to Judge Walker's chambers with all necessary counsel on the line. (SR)

Minute Entry for proceedings held before Magistrate Judge Robert H. Walker: Telephonic Status Conference held on 6/9/2016 with attorneys J. Cliff Johnson and LaShundra B. Jackson-Winters who advised that the case settled. The attorneys are directed to submit a proposed final judgment to Judge Lee no later than Friday, June 17, 2016. (SR)

DECLARATORY JUDGMENT: it violates the Constitution to incarcerate an individual, either before or after trial, solely because an individual does not have the ability to make a monetary payment. Signed by District Judge Tom S. Lee on 6/20/16 (LWE) (Entered: 06/20/2016)

FINAL JUDGMENT dismissing plaintiff's claims with prejudice. Signed by District Judge Tom S. Lee on 6/20/16. (RRL) (Entered: 06/20/2016)

MOTION to Intervene by Professional Bail Agents Association of Mississippi, Inc. (Attachments: # 1 Exhibit Proposed Motion to Alter or Amend Final Judgment, or in the Alternative, for Relief from Final Judgment, # 2 Exhibit Proposed Memorandum Brief in Support of Motion to Alter or Amend Final Judgment, or in the Alternative, for Relief from Final Judgment, # 3 Exhibit Complaint in Jenkins vs. City of Jennings, # 4 Exhibit Judgment in Jenkins vs. City of Jennings, # 5 Exhibit Complaint in Kennedy vs. City of Biloxi, # 6 Exhibit Settlement Agreement in Kennedy vs. City of Biloxi, # 7 Exhibit Complaint in Thompson vs. City of Moss Point, # 8 Exhibit Final Judgment in Thompson vs. City of Moss Point, # 9 Exhibit Unopposed Motion for Joinder of Parties in Mitchell vs. City of Montgomery, # 10 Exhibit Declaration of Wayne Dowdle)(Smith, Christopher) (Entered: 06/28/2016)

1 Exhibit Proposed Motion to Alter or Amend Final Judgment, or in the Alternative,

View on RECAP

2 Exhibit Proposed Memorandum Brief in Support of Motion to Alter or Amend Final J

View on PACER

3 Exhibit Complaint in Jenkins vs. City of Jennings

View on PACER

4 Exhibit Judgment in Jenkins vs. City of Jennings

View on PACER

5 Exhibit Complaint in Kennedy vs. City of Biloxi

View on PACER

6 Exhibit Settlement Agreement in Kennedy vs. City of Biloxi

View on PACER

7 Exhibit Complaint in Thompson vs. City of Moss Point

View on PACER

8 Exhibit Final Judgment in Thompson vs. City of Moss Point

View on PACER

9 Exhibit Unopposed Motion for Joinder of Parties in Mitchell vs. City of Montgome

View on PACER

10 Exhibit Declaration of Wayne Dowdle

View on PACER

MEMORANDUM in Support re 15 MOTION to Intervene filed by Professional Bail Agents Association of Mississippi, Inc. (Smith, Christopher) (Entered: 06/28/2016)

RESPONSE in Opposition re 15 MOTION to Intervene filed by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Howard, Jacob) (Entered: 07/12/2016)

MEMORANDUM in Opposition re 15 MOTION to Intervene filed by Jerome Bell, Domonic Butler, Michael Davis, Marteze Harris, Ricky Lambert, James Sheppard, Jarmale Walker (Attachments: # 1 Exhibit Exhibit A - McComb Order)(Howard, Jacob) (Entered: 07/12/2016)

1 Exhibit Exhibit A - McComb Order

View on PACER

RESPONSE in Opposition re 15 MOTION to Intervene filed by The City of Jackson, Mississippi (Jackson-Winters-City Gov, LaShundra) (Entered: 07/12/2016)

Rebuttal re 19 Response in Opposition to Motion to Intervene filed by Professional Bail Agents Association of Mississippi, Inc. (Holder, G.) (Entered: 07/20/2016)

ORDER denying 15 Motion to Intervene field by Professional Bail Agents Association of Mississippi. (party terminated) Signed by District Judge Tom S. Lee on 8/25/16 (LWE) (Entered: 08/25/2016)