Williams v. Dart

Federal 7th Circuit Court
Civil Court
Bail
Citation
Case Number: 
No. 19-2108
Decision Date: 
July 23, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed and reversed in part and remanded

Dist. Ct. erred in dismissing for failure to state viable claim plaintiffs’ (individuals who had been released on bail) section 1983 action alleging that defendant-Sheriff improperly detained them from three to fourteen days after entry of trial court’s bail release order because he essentially disagreed with trial court’s release order. Plaintiffs adequately alleged claim under Fourth Amendment for wrongful pre-trial custody, where: (1) plaintiffs alleged that in place of court-ordered release on specified terms, defendant substituted prolonged detentions, as well as significant restraints on pretrial release of his own devising; and (2) such decisions to delay release was not defendant’s to make. Moreover, Ct. found that instant alleged delays could not be justified on basis of administrative delay. Also, plaintiffs stated adequate equal protection claim, where plaintiffs maintained that defendant targeted plaintiffs for detention because of their race, and where defendant’s bail review policy disproportionately targeted African-American inmates. Plaintiffs also adequately alleged state-law claim alleging that defendant contumaciously refused to comply with trial court bail release orders that were legally issued to him. While defendant argued that bail orders requiring him to monitor plaintiffs on bail could not be binding on him because he had not agreed to said monitoring, defendant’s argument could not be resolved on pleadings.