Filed Date: Jan. 1, 2017
Closed Date: Dec. 13, 2018
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In this case, a Memphis criminal defendant challenged the constitutionality of Tennessee’s cash bail system. In early of 2017, the defendant and, later, petitioner, was charged with attempted first degree murder. The Tennessee trial court set bail at $200,000, which he could not pay, leading to his incarceration while his criminal case was pending. The defendant was initially represented by the Shelby County Public Defender. He claimed that the trial court set a high bail amount with the goal of detaining him, causing him to be incarcerated because of his poverty. This, he said, was a
violation of his Fourteenth Amendment Due Process and Equal Protection rights, as well as his rights under the Tennessee Constitution and state statutes.
The defendant initially had his bail set in the Shelby County General Sessions Court on January 1, 2017. He appealed that bail determination to the Tennessee Criminal Court on March 22, 2017, where the case was docketed as P43279. In both courts, he argued that he was entitled to a bail determination based on his risk of flight or dangerousness to the community, the standard used in federal court. However, as was the common practice in Tennessee, the court made no determination on these issues, but set a high bail that it knew the defendant would be unable to afford with the express goal of having him detained before trial. Both the General Sessions Court and the Criminal Court rejected these arguments and the defendant was detained.
In response, the defendant filed a motion raising the same arguments under Rule 8 of the Tennessee Rules of Appellate Procedure, which allows defendant to appeal bail decisions to the Tennessee Court of Criminal Appeals on April 19, 2017. That case was docketed as W2017-00779-SC-R8-CO. In a May 11, 2017, the Court of Criminal Appeals affirmed the Criminal Court’s bail determination, noting that Tennessee trial courts have “very wide latitude in setting bail.”
The defendant filed a similar motion in Tennessee Supreme Court on May 30, 2017, where the case was again docketed as W2017-00779-SC-R8-CO. Civil Rights Corp and the ACLU of Tennessee both filed an amicus brief in support of his release. However, on June 8, 2017 the Tennessee Supreme Court denied that motion in a two sentence order, affirming the trial court again.
Though the defendant had exhausted all of his state appeals, he continued to challenge his pretrial detention. Joined by Civil Rights Corps, the MacArthur Justice Center, and private counsel, he filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241 in the U.S. District Court for the Western District of Tennessee on July 25, 2017. There, the case was docketed as Weatherspoon v. Oldham, 2:17-cv-02535 and assigned to U.S. District Judge Samuel H. Mays, Jr.
On February 26, 2018, Judge Mays granted the defendant’s petition. 2018 WL 1053548. He found that the defendant was deprived of his liberty without Due Process by Tennessee’s cash bail scheme because the proceedings did not consider the defendant’s risk of flight or danger to the community. However, he did not reach the defendant’s Equal Protection argument. Judge Mays granted the defendant a conditional writ of habeas corpus, ordering him released unless the Criminal Court held a bail hearing that comported with the requirements of the Due Process clause within 30 days.
However, the defendant filed a motion for reconsideration of Judge Mays’ order on March 2, 2018 asking the court to require a clear and convincing standard in his state bail hearing. On April 19, 2018, the court denied this motion, finding no reason to reconsider his prior decision. 2018 WL 1884825.
The state court later reduced the defendants bail to $100,000 and ordered that he be subject to GPS monitoring if released. However, it does not appear that he was released. The defendant then filed an emergency motion alleging the Tennessee court on March 29, 2018, alleging that the state trial court violated his Due Process rights by not finding that no condition of non-monetary conditions could ensure his return to court or the safety of the community. Judge Mayes disagreed with that assessment in a May 1, 2018 order, which found that the state court's decision comported with the requirements of the Due Process clause.
Judgement was entered in the federal case on May 1, 2018 and there has no been no activity since that date. Tennessee Department of Corrections show that the defendant was eventually convicted and sentenced in his criminal case, thus mooting the question of his pretrial incarceration. Thus, the case is closed.
Summary Authors
Jonah Hudson-Erdman (7/20/2021)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6317272/parties/weatherspoon-v-oldham/
Claxton, Charmiane G. (Tennessee)
Ali, Amir H. (District of Columbia)
Bush, Stephen C (Tennessee)
Davis Redden, Emma J (Tennessee)
Castelli, Thomas H. (Tennessee)
Claxton, Charmiane G. (Tennessee)
Glenn, Alan E. (Tennessee)
Mays, Samuel H. Jr. (Tennessee)
McMullen, Camille R. (Tennessee)
Williams, John Everett (Tennessee)
See docket on RECAP: https://www.courtlistener.com/docket/6317272/weatherspoon-v-oldham/
Last updated March 27, 2024, 3:13 a.m.
State / Territory: Tennessee
Case Type(s):
Special Collection(s):
Fines/Fees/Bail Reform (Criminalization of Poverty)
Key Dates
Filing Date: Jan. 1, 2017
Closing Date: Dec. 13, 2018
Case Ongoing: No
Plaintiffs
Plaintiff Description:
a criminal defendant detained under Tennessee's cash bail scheme
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State of Tennessee (Memphis, Shelby), State
Sheriff (Memphis, Shelby), County
Case Details
Causes of Action:
Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Due Process: Procedural Due Process
Special Case Type(s):
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Issues
General: