Case: Robinson v. Martin

16-13597 | Illinois state trial court

Filed Date: Oct. 14, 2016

Clearinghouse coding complete

Case Summary

Two men incarcerated in Cook County, Illinois, filed this class action lawsuit on October 14, 2016, in the Circuit Court of Cook County. The plaintiffs were eligible for release from jail but were detained because they could not afford the required bail. They brought their claims against a group of judges in the Circuit Court of Cook County who had routinely applied Illinois's bail statute to set monetary bail in amounts higher than individuals were able to pay. They also included the Sheriff o…

Two men incarcerated in Cook County, Illinois, filed this class action lawsuit on October 14, 2016, in the Circuit Court of Cook County. The plaintiffs were eligible for release from jail but were detained because they could not afford the required bail. They brought their claims against a group of judges in the Circuit Court of Cook County who had routinely applied Illinois's bail statute to set monetary bail in amounts higher than individuals were able to pay. They also included the Sheriff of Cook County as a defendant. The plaintiffs alleged that the judicial defendants engaged in this practice without inquiring into arrestees' ability to pay and provided no alternative for those who were indigent. As a result, thousands of people awaiting trial were held in Cook County jails simply because they were poor. Consequently, many lost their jobs, homes, custody of their children, and suffered other adverse consequences, including a higher likelihood of conviction. The plaintiffs also alleged that a disproportionate number of detained individuals were African American.

Represented by the MacArthur Justice Center, the Civil Rights Corps, and private counsel, the plaintiffs brought claims under 42 U.S.C. § 1983, alleging violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the U.S. Constitution, the Equal Protection and Due Process Clauses of the Illinois Constitution (Article One, Section Two), the Excessive Bail Clause of the Eighth Amendment to the U.S. Constitution, the Bailable by Sufficient Sureties Clause of the Illinois Constitution (Article One, Section 9), and the Illinois Civil Rights Act of 2003. The plaintiffs sought declaratory and injunctive relief to enjoin defendants from unlawfully incarcerating those detained only because of inability to pay bail.

The plaintiffs filed an amended complaint on March 17, 2017. On April 14, the defendants filed a motion to dismiss, arguing that the plaintiffs' amended complaint was moot because a General Order issued by the Cook County Circuit Court Chief Judge adequately addressed their complaint. Based on the plaintiffs' response to the motion to dismiss, it appears the General Order was issued in response to plaintiffs' complaint and directed all circuit judges to follow certain procedures with respect to setting bail. It was set to go into effect in September of 2017 for felony cases and January of 2018 for all other cases. In their response motion to the defendants' motion to dismiss, the plaintiffs argued that the General Order did not have the force of law necessary to adequately address the plaintiffs' claims.

However, on June 26, 2018, Judge Celia Gamrath granted the defendants' motion to dismiss. Judge Gamrath found that various doctrines barred the plaintiffs' claims. She also noted that Illinois's bail reform legislation "change[d] the landscape for bond hearings for arrestees" and directed the plaintiffs to the legislature to effectuate further changes in the state's bail system. The plaintiffs appealed this ruling, but later voluntarily dismissed the appeal. The case is presumably closed.

Summary Authors

Lauren Latterell Powell (1/11/2018)

Jonah Hudson-Erdman (9/7/2021)

People


Judge(s)

Gamrath, Celia G (Illinois)

Attorneys(s) for Plaintiff

Badlani, Chirag (Illinois)

Bowman, Locke E. III (Illinois)

Karakatsanis, Alec (District of Columbia)

Piers, Matthew J. (Illinois)

Robinson, Zachary (Illinois)

Schwartz, Kate E. (Illinois)

VanBrunt, Alexa (Illinois)

Attorneys(s) for Defendant

Martin, Leroy Jr. (Illinois)

Judge(s)

Gamrath, Celia G (Illinois)

Attorneys(s) for Plaintiff

Badlani, Chirag (Illinois)

Bowman, Locke E. III (Illinois)

Karakatsanis, Alec (District of Columbia)

Piers, Matthew J. (Illinois)

Robinson, Zachary (Illinois)

Schwartz, Kate E. (Illinois)

VanBrunt, Alexa (Illinois)

Attorneys(s) for Defendant

Martin, Leroy Jr. (Illinois)

Documents in the Clearinghouse

Document

Docket

Nov. 22, 2017 Docket
1

Class Action Complaint

Oct. 14, 2016 Complaint

Plaintiffs' Response in Opposition to Defendants' Supplemental 2-619 Motion to Dismiss for Mootness

Aug. 14, 2017 Pleading / Motion / Brief

Order Granting Section 2-619.1 Motion to Dismiss

Robinson v. Martin Jr

June 26, 2018 Order/Opinion

Resources

Title Description External URL

Robinson v. Martin

Locke Bowman and Alexa Van Brunt

The MacArthur Justice Center partnered with Hughes Socol Piers Resnick & Dym, Ltd. and Civil Rights Corps to file a federal class action targeting Cook County’s unconstitutional pay-for-release cash … Oct. 14, 2016 https://www.macarthurjustice.org/case/robinson-v-martin/

Cook County, IL: Bail

Civil Rights Corps

Civil Rights Corps is challenging the unconstitutional money bail in Cook County, Illinois. Our lawsuit alleges that the money bail system that pervaded the Chicago region, in which people are kept i… July 25, 2017 http://www.civilrightscorps.org/work/case/cook-county-il-bail

Docket

Last updated May 11, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: Illinois

Case Type(s):

Criminal Justice (Other)

Special Collection(s):

Fines/Fees/Bail Reform (Criminalization of Poverty)

Key Dates

Filing Date: Oct. 14, 2016

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Individuals detained in Cook County, Illinois, jails solely because of inability to pay bail.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

MacArthur Justice Center

Civil Rights Corps

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

Cook County, Illinois (Cook), County

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

State law

Constitutional Clause(s):

Due Process

Equal Protection

Availably Documents:

Trial Court Docket

Complaint (any)

Non-settlement Outcome

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Courts

Disparate Impact

Fines/Fees/Bail/Bond

Over/Unlawful Detention

Discrimination-basis:

Race discrimination

Race:

Black