Brown v. Chase

462 F. Supp. 938, 1978 U.S. Dist. LEXIS 6959
CourtDistrict Court, D. Vermont
DecidedDecember 29, 1978
DocketCiv. A. No. 78-273
StatusPublished
Cited by1 cases

This text of 462 F. Supp. 938 (Brown v. Chase) is published on Counsel Stack Legal Research, covering District Court, D. Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Chase, 462 F. Supp. 938, 1978 U.S. Dist. LEXIS 6959 (D. Vt. 1978).

Opinion

HOLDEN, Chief Judge.

MEMORANDUM OF DECISION

The petitioner’s pretrial release was revoked for violation of a condition of release imposed by the Vermont District Court, Unit # 6, Windham Circuit. The condition was that the petitioner:

not be the subject of a new charge of a felony or a crime against a person or a like offense to the offense charged for which, after hearing, probable cause is found.1

The requirement was one of several imposed as a condition of pretrial release.2 The petitioner is presently confined in the Woodstock Correctional Facility pursuant to the court order revoking bail.3

The petitioner appealed his bail revocation to the Vermont Supreme Court and a single Justice of that Court affirmed the lower court’s order.4 The petitioner now seeks relief in this court under 28 U.S.C. § 2254, asking that he be released from confinement pending his trial. Oral argument on this application was held on December 6, 1978.

Petitioner argues here, as he did to the Vermont Supreme Court, that the condition imposed was unconstitutional and, further, even if it were proper, that the manner in which he was found to have violated it transgressed his rights to due process of law. More fully, the petitioner claims that bail revocation proceedings constitute a deprivation of liberty within the teaching of Morrissey v. Brewer, 408 U.S. 471, 92 S.Ct. 2593, 33 L.Ed.2d 484 (1972) and Gagnon v. Scarpelli, 411 U.S. 778, 93 S.Ct. 1756, 36 L.Ed.2d 656 (1973), and that the same opportunities to be heard and to contest are required at bail revocation as Morrissey and Scarpelli mandated for the revocation of parole and probation.

Both arguments raise substantial questions. However, upon examination of the record of the state court proceedings, the court concludes that the application for habeas corpus relief must be denied.

[940]*940 I. Conditions of Release

The petitioner’s first argument is that the condition he was found to have violated does not meet the requirements of Stack v. Boyle, 342 U.S. 1, 72 S.Ct. 1, 96 L.Ed. 3 (1951). In particular, the claim is that the condition was designed to protect the community against dangers presented by the petitioner’s behavior, not merely to assure his presence at trial. The trial judge’s written findings and conclusions on the State’s motion to show cause why the defendant should not be found in violation of the conditions of his release lend some support to this theory.5 But it cannot be gainsaid that breach of the condition at issue here would be probative of increased danger of failure to appear at trial. As Justice Billings of the Vermont Supreme Court explained:

There are a number of reasons why the breach of a condition imposed for other reasons might bear convincingly on the issue of an accused’s likelihood of returning to face trial. The multiplication of charges against the accused and the mounting of evidence against him might make a defendant’s appearance less likely. The violations charged upon probable cause might well be probative of a lack of regard for the statutes of the state or the orders of the court.6

Since the condition imposed was relevant “to the purpose of assuring the presence of [the] defendant” at trial, it squares with the constitutional standards referred to in Stack v. Boyle, supra, 342 U.S. at 6, 72 S.Ct. at 4.

II. Revocation of Release [2] It is now fundamental that one who suffers a “grievous loss” of a “liberty” or a “property” at the hands of the government is entitled to the procedural protections of the Fifth and Fourteenth Amendments. See, e. g., Goldberg v. Kelly, 397 U.S. 254, 90 S.Ct. 1011, 25 L.Ed.2d 287 (1970). The Supreme Court’s decision in Morrissey v. Brewer, 408 U.S. 471, 92 S.Ct. 2593, 33 L.Ed.2d 484 (1972) determined that revocation of parole constituted the “grievous loss” of a “liberty.” The Court explained that the parolee:

. can be gainfully employed and is free to be with family and friends and to form the other enduring attachments of normal life. Though the State properly subjects him to many restrictions not applicable to other citizens, his condition is very different from that of confinement in a prison. He may have been on parole for a number of years and may be living a relatively normal life at the time he is faced with revocation. The parolee has relied on at least an implicit promise [941]*941that parole will be revoked only if he fails to live up to the parole conditions.

408 U.S. at 482, 92 S.Ct. at 2600-01. (Citations omitted.) The Court concluded:

We see, therefore, that the liberty of a parolee, although indeterminate, includes many of the core values of unqualified liberty and its termination inflicts a “grievous loss” on the parolee and often on others.

Id.

At the next term, the Court held:

Probation revocation, like parole revocation, is not a stage of criminal prosecution, but does result in a loss of liberty. Accordingly, we hold that a probationer, like a parolee, is entitled to a preliminary and a final revocation hearing, under the conditions specified in Morrissey v. Brewer, supra.

Gagnon v. Scarpelli, supra, 411 U.S. at 782, 93 S.Ct. at 1759-60.

The person on pretrial release has the same employment opportunities and family contacts as does the parolee. The person on pretrial release has additional interests, not shared by the parolee:

This traditional right to freedom before conviction permits the unhampered preparation of a defense, and serves to prevent the infliction of punishment prior to conviction.

Stack v. Boyle, supra, 342 U.S. at 4, 72 S.Ct. at 3 (1951). For these reasons the court finds that persons on pretrial release suffer a “grievous loss” of “liberty” when their release is revoked. Under Morrissey and Scarpelli, therefore, some sort of an adversary hearing is required before this liberty can be terminated.

The petitioner contends that no adversary hearing at all was afforded him; that he was entitled to procedural safeguards stated in Morrissey7 The record does not bear out this aspect of his claim. It demonstrates that the petitioner was present, with counsel, at the hearing before the Vermont District Court, which resulted in the termination of his pretrial release. The record of the hearing indicates that petitioner’s counsel urged that the revocation hearing would not satisfy due process, citing the Vermont Supreme Court’s recent decision in State v. Knight, 135 Vt. 453,

Related

Estrada v. State
594 S.W.2d 445 (Court of Criminal Appeals of Texas, 1980)

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Bluebook (online)
462 F. Supp. 938, 1978 U.S. Dist. LEXIS 6959, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-chase-vtd-1978.