Robert Pugh and Nathaniel Henderson v. James Rainwater

572 F.2d 1053, 1978 U.S. App. LEXIS 11245
CourtCourt of Appeals for the Fifth Circuit
DecidedMay 10, 1978
Docket72-1223
StatusPublished
Cited by81 cases

This text of 572 F.2d 1053 (Robert Pugh and Nathaniel Henderson v. James Rainwater) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Pugh and Nathaniel Henderson v. James Rainwater, 572 F.2d 1053, 1978 U.S. App. LEXIS 11245 (5th Cir. 1978).

Opinions

VANCE, Circuit Judge:

The panel opinion, 557 F.2d 1189, traces the complicated history of this litigation.1 Before the Court on rehearing en banc is plaintiffs’ contention and the panel’s holding that Florida Rule of Criminal Procedure 3.130(b)(4), does not pass constitutional muster. The rule was adopted by the Supreme Court of Florida while the case was pending in this Court. Effective on July 1, 1977 it established the pretrial bail system which is the present successor to the bail practices upheld by the Southern District of Florida in the judgment from which this appeal originally was taken.

The new rule2 enumerates six forms of release which come within the definition of bail in non-capital cases. Number five is the posting of a bail bond with sureties or the deposit of cash in lieu thereof. It is [1056]*1056urged that in the case of indigents, equal protection standards require a presumption against money bail and favoring the other enumerated forms of release.3 The panel held that Florida’s new rule is constitutionally defective by reason of its failure to express such a presumption. We disagree.

At the outset we accept the principle that imprisonment solely because of indigent status is invidious discrimination and not constitutionally permissible. Williams v. Illinois, 399 U.S. 235, 90 S.Ct. 2018, 26 L.Ed.2d 586 (1970); Tate v. Short, 401 U.S. 395, 91 S.Ct. 668, 28 L.Ed.2d 130 (1971). The punitive and heavily burdensome nature of pretrial confinement has been the subject of convincing commentary.4 We view such deprivation of liberty of one who is accused but not convicted of crime as presenting a question having broader effects and constitutional implications than would appear from a rule stated solely for the protection of indigents.

Resolution of the problems concerning pretrial bail requires a delicate balancing of the vital interests of the state with those of the individual. Florida has a compelling interest in assuring the presence at trial of persons charged with crime.5 Yet such individuals remain clothed with a presumption of innocence and with their constitutional guarantees intact. The Supreme Court speaking through Chief Justice Vinson observed in Stack, et a1. v. Boyle, United States Marshal, 342 U.S. 1, 4, 72 S.Ct. 1, 3, 96 L.Ed. 3 (1951):

“From the passage of the Judicial Act of 1789,1 Stat. 73, 91, to the present Federal Rules of Criminal Procedure, Rule 46(a)(1) [18 U.S.C.A.] federal law has unequivocally provided that a person arrested for a non-capital offense shall be admitted to bail. This traditional right to freedom before conviction permits the unhampered preparation of a defense, and serves to prevent the infliction of [1057]*1057punishment prior to conviction. See Hudson v. Parker, 1895, 156 U.S. 277, 285 [15 S.Ct. 450, 39 L.Ed. 424] (1895). Unless this right to bail before trial is preserved, the presumption of innocence, secured only after centuries of struggle, would lose its meaning.
“The right to release before trial is conditioned upon the accused’s giving adequate assurance that he will stand trial and submit to sentence if found guilty. Ex parte Milburn, 1835, 9 Pet. 704, 710 [9 L.Ed. 280] (1835). Like the ancient practice of securing the oaths of responsible persons to stand as sureties for the accused, the modern practice of requiring a bail bond or the deposit of a sum of money subject to forfeiture serves as additional assurance of the presence of an accused. Bail set at a figure higher than an amount reasonably calculated to fulfill this purpose is ‘excessive’ under the Eighth Amendment. See United States v. Motlow, 10 F.2d 657 (1926, opinion by Mr. Justice Butler as Circuit Justice of the Seventh Circuit).
“Since the function of bail is limited, the fixing of bail for any individual defendant must be based upon standards relevant to the purpose of assuring the presence of that defendant. * * * ”

In another context the rule was established in Rhem v. Malcolm, 507 F.2d 333, 336 (2d Cir. 1974), that:

“The demands of equal protection of the laws and of due process prohibit depriving pre-trial detainees of the rights of other citizens to a greater extent than necessary to assure appearance at trial and security of the jail; * * * ”

See to the same effect: Taylor v. Sterrett, 532 F.2d 462 (5th Cir. 1976); Duran v. El-rod, 542 F.2d 998 (7th Cir. 1976); United States, ex rel. Tyrrell v. Speaker, 535 F.2d 823 (3rd Cir. 1976). Such requirement as is necessary to provide reasonable assurance of the accused’s presence at trial is constitutionally permissible. Any requirement in excess of that amount would be inherently punitive and run afoul of due process requirements.

The argument favoring a specified priority sequence for the various forms of release overlooks the fact that its impact may vary under varying circumstances. By definition an indigent is incapable of meeting any money bail requirement. Similarly disfavored is the non-indigent whose money bail is set in an amount higher than he can provide. Money bail, however, may not be the most burdensome requirement in all cases. A moneyed visitor in a city far removed from his home might find certain of the alternative forms of release infinitely more onerous. Utilization of a master bond schedule6 provides speedy and convenient release for those who have no difficulty in meetings its requirements. The incarceration of those who cannot, without meaningful consideration of other possible alternatives, infringes on both due process and equal protection requirements.

Rules under which personal liberty is to be deprived are limited by the constitutional guarantees of all, be they moneyed or indigent, befriended or friendless, employed or unemployed, resident or transient, of good reputation or bad.

The ultimate inquiry in each instance is what is necessary to reasonably assure defendant’s presence at trial. Systems which incorporate a presumption favoring personal recognizance avoid much of the difficulty inherent in the entire subject area. A mechanical consideration of priorities among various other modes of release may conform to constitutional requirements.7 We per[1058]*1058ceive no reason, however, why less explicit requirements may not be applied in an altogether constitutional manner. We have no doubt that in the case of an indigent, whose appearance at trial could reasonably be assured by one of the alternate forms of release, pretrial confinement for inability to post money bail would constitute imposition of an excessive restraint. We do not read the State of Florida’s new rule to require such a result.

It is here that we reach a fundamental point of departure from the panel’s decision.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Salinas v. Ramirez
S.D. Texas, 2025
Edwards v. Cofield
M.D. Alabama, 2025
Melancon v. Walsh
Fifth Circuit, 2025
Torres v. Collins
E.D. Tennessee, 2023
CHAPMAN v. CHUDZIK
E.D. Pennsylvania, 2023
Morris v. Gonzalez
S.D. Texas, 2023
Bradley Hester v. Matthew Gentry
Eleventh Circuit, 2022
Daves v. Dallas County
22 F.4th 522 (Fifth Circuit, 2022)
Dixon v. City of St. Louis
E.D. Missouri, 2021
In re Humphrey
482 P.3d 1008 (California Supreme Court, 2021)
United States v. Emakoji
990 F.3d 885 (Fifth Circuit, 2021)
Daves v. Dallas Cty
984 F.3d 381 (Fifth Circuit, 2020)
Feltz v. Regalado
N.D. Oklahoma, 2020
Motley v. Taylor
M.D. Alabama, 2020
Muhammad v. Wiles
W.D. Texas, 2020

Cite This Page — Counsel Stack

Bluebook (online)
572 F.2d 1053, 1978 U.S. App. LEXIS 11245, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-pugh-and-nathaniel-henderson-v-james-rainwater-ca5-1978.