Filed Date: Jan. 18, 2018
Case Ongoing
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This case was filed on January 18, 2018 by Missouri public defender Stephen Reynolds in St. Louis County Circuit Court in Missouri. The case was filed in the form of a "Motion Requesting Conference to Discuss Caseload Issues," pursuant to a Missouri statute that allowed individual public defenders to notify the court of excessive caseloads. However, the motion was unusual in that it concerned the caseload of the entire St. Louis County public defender's office. The filing followed approximately a year's worth of out-of-court meetings between the public defender's office and the St. Louis County courts and prosecutors regarding what the public defender's office viewed as ethical and constitutional issues arising from excessive caseloads for public defenders.
The motion was granted and the hearing took place on February 16, 2018. It consisted of an on-the-record conference between Judge Douglas Beach, senior county prosecutors, and representatives of the public defender's office. At the conference, the public defender's office introduced statistical evidence showing the office's workload on an attorney-by-attorney basis, and alleged that the workload was excessive when assessed in light of relevant scholarship. Furthermore, the defender's office requested relief pursuant to the law under which the motion had been filed, asking the court to grant continuances, assign cases to private counsel, and decline to incarcerate defendants for alleged probation violations.
On March 19, 2018, Judge Beach issued an order granting in part the public defender's office's request for caseload relief. Judge Beach stressed that the statute under which the motion was filed was intended to address individual defenders, rather than office-wide issues. Therefore the judge declined to apply relief on an office-wide basis.
However, Judge Beach found "cognizable reasons" to believe that a group of 20 public defenders had excessive caseloads which prevented them from carrying out ethical obligations to clients. The judge ordered that a maximum number of cases per public defender would be designated, and that henceforth cases would not be assigned to attorneys in excess of the designated number. The order mandated the appointment of private attorneys in certain drug offense cases, where necessary to maintain appropriate public defender workload. Furthermore, Judge Beach ordered that defendants in probation hearings and other proceedings be screened and only referred to a public defender if representation was required by the due process clauses of the United States and Missouri Constitutions.
On April 2, 2018, Judge Beach's order was appealed by the St. Louis County prosecutor's office. On December 26, 2018, the Missouri Court of Appeals, Eastern District (Judge James Dowd) issued an opinion referring the matter directly to the Missouri Supreme Court "because of the general interest and importance of the issues presented." Judge Dowd explained in a detailed opinion that notwithstanding his referral, he would have reversed the order granting relief to the public defenders and instruct that the matter be resolved as an "administrative action" regarding docket organization, rather than a "court-tried civil action." In Judge Dowd's view, the statute only authorized administrative actions rather than full fledged civil cases. 2018 WL 6787054.
As of February 15, 2019, the case has been accepted for referral by the Missouri Supreme Court. On January 8, 2019, the supreme court's docket was updated to reflect that the prosecutor's office had withdrawn their appeal of the matter. The current status of the case is unclear.
Summary Authors
Nathaniel Flack (2/15/2019)
Beach, Douglas R (Missouri)
Beach, Douglas R (Missouri)
Last updated Aug. 30, 2023, 1:47 p.m.
Docket sheet not available via the Clearinghouse.State / Territory: Missouri
Case Type(s):
Key Dates
Filing Date: Jan. 18, 2018
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Missouri public defenders, St. Louis County
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
St. Louis County (St. Louis), County
Case Details
Causes of Action:
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Unknown
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Issues
General: