Filed Date: Dec. 5, 2017
Closed Date: July 6, 2021
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This was a case about excessive fines and fees. Plaintiffs were private citizens of Corinth, MS bringing a class action complaint against the City of Corinth and Municipal Court Judge John C. Ross. The action was brought in the U.S. District Court for the Northern District of Mississippi on December 5, 2017. Plaintiffs are represented by Southern Poverty Law Center and MacArthur Justice Center. The action was brought under 42 U.S.C. § 1983 and 28 U.S.C. § 2201 (The Declaratory Relief Act), and alleged violations of the plaintiffs' Fourteenth Amendment Due Process and Equal Protection rights, Sixth Amendment right to counsel, and Fourth Amendment right to timely probable cause determination. The case was assigned to Judge Debra M. Brown and Magistrate Judge David A. Sanders.
In the complaint, plaintiffs alleged they were arrested and held in jail because they could not pay the bond required. The city's policies did not inquire into the detainee’s finances, resulting in alleged systematic wealth-based detention. The city had a once-weekly municipal court date, which could result in detainees being held up to ten days before their initial hearing. Finally, they alleged the judge did not review financial conditions of release and jailed or threatened to jail individuals who could not pay fines or court costs. The plaintiffs sought declaratory relief that the City of Corinth had violated the class members’ rights under the Fourth, Sixth, or Fourteenth Amendments, sought injunctive relief to prevent the city from detaining any members of the class because they could not afford bail, and for the city to make a probable cause determination within 48 hours of an arrest. Simultaneous with the complaint, the plaintiffs filed a motion for preliminary injunction.
The plaintiffs also sought class certification of three separate classes, distinguished by the legal issues at stake. The Bail Class was based on the questions of if defendants have a policy or practice of detaining individuals who cannot pay the amount required by the bail schedule and if this bail schedule is predetermined, and whether these policies violated the Fourteenth Amendment’s Due Process and Equal Protection clauses. The Probable Cause Class was based on the defendant’s policy and practice of holding municipal court once a week, and whether this violated the Fourth Amendment. The Pay-or-Stay Class was based on the defendant’s practice of not assessing alternatives to jailing for nonpayment and not evaluating the ability to pay, and if these violated the Sixth and Fourteenth Amendment.
On April 25, 2018 the parties filed a settlement agreement with the court which provided that the city would implement the procedures contained in the Corinth Municipal Court Procedures, as well as a plan for dissemination of procedures and training. The procedures required the initial hearing to take place within 48 hours of the arrest, prohibited jailing only because of inability to pay bail or fines, and required the judge to evaluate the individual’s ability to pay bail. The settlement was to be enforced by the court for three years, and the case dismissed. Judge Brown granted the settlement on July 6, 2018 and there have been no further docket entries; the case is now closed.
Summary Authors
Misha Emanoil (2/3/2022)
See docket on RECAP: https://www.courtlistener.com/docket/6376641/brown-v-city-of-corinth/
Last updated March 17, 2023, 3:05 a.m.
State / Territory: Mississippi
Case Type(s):
Special Collection(s):
Fines/Fees/Bail Reform (Criminalization of Poverty)
Key Dates
Filing Date: Dec. 5, 2017
Closing Date: July 6, 2021
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Two individuals, on behalf of a putative class, who were held in jail because they could not pay the required bond
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Mooted before ruling
Defendants
City of Corinth (Corinth, Alcorn), City
Municipal Court Judge of Corinth Municipal Court, City
Case Details
Causes of Action:
Declaratory Judgment Act, 28 U.S.C. § 2201
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Mixed
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Issues
General:
Access to lawyers or judicial system