University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Dixon v. City of St. Louis CJ-MO-0023
Docket / Court 4:19-cv-00112 ( E.D. Mo. )
State/Territory Missouri
Case Type(s) Criminal Justice (Other)
Special Collection Fines/Fees/Bail Reform (Criminalization of poverty)
Attorney Organization Advancement Project
ArchCity Defenders
Civil Rights Corps
Case Summary
On January 28, 2019, several arrestees from St. Louis filed this class action lawsuit in the U.S. District Court for the Eastern District of Missouri. None of the plaintiffs could afford to pay their monetary release conditions, which ranged from $10,000 to $30,000, and were thus incarcerated at ... read more >
On January 28, 2019, several arrestees from St. Louis filed this class action lawsuit in the U.S. District Court for the Eastern District of Missouri. None of the plaintiffs could afford to pay their monetary release conditions, which ranged from $10,000 to $30,000, and were thus incarcerated at once of the City’s two detention centers without access to showers or medical care and forced to endure unconscionable conditions, including extreme heat and cold, rat and cockroach infestations, mold, and abuse of inmates by jail guards.

They sued the City of St. Louis, its officers, and all judges in the 22nd Judicial Circuit Court of Missouri under 42 U.S.C. § 1983 and 28 U.S.C. §2201. The case was ultimately assigned to Judge Audrey G. Fleissig. The Plaintiffs were represented by a collection of public interest organizations including ArchCity Defenders, the Advancement Project, Civil Rights Corps, and the Institute for Constitutional Advocacy and Protection. They sought class certification as “all arrestees who are or will be detained in the Medium Security Institution (referred to as ‘the Workhouse’) or the City Justice Center (‘CJC), operated by the City of St. Louis, post-arrest because they are unable to afford to pay a monetary release condition.”

The Plaintiffs sought a declaratory judgment that Defendants had violated the Plaintiffs’ Fourteenth Amendment rights, a temporary restraining order requiring the Sheriff and Commissioner of Corrections to release the Plaintiffs unless they were provided a hearing, and injunctive relief to permanently enjoin Defendants from implementing a wealth-based pretrial detention system. They later sought a preliminary injunction to restrain the Defendants from implementing allegedly unconstitutional orders of detention. Specifically, they claimed that the Defendants violated their Equal Protection and Due Process rights by setting arbitrary monetary release conditions that exceed an individual’s ability to pay and detaining Plaintiffs solely on their inability to pay. They also claimed that Plaintiffs' pretrial detention infringed upon a fundamental right and violated their Substantive Due Process rights. Finally, they claimed that Defendants violated Plaintiffs’ Procedural Due Process rights by detaining them for weeks before giving them a hearing or opportunity to challenge or modify their release conditions.

On January 30, 2019, the parties reached a Stipulation Agreement prior to the temporary restraining order hearing. The Agreement provided that a Judge of the 22nd Judicial Circuit would hold a hearing for each Named Plaintiff regarding their conditions of release before the end of the day on January 31, 2019. The Agreement also provided that the Defendant Judges would comply with the Missouri Supreme Court Rules regarding the conditions of release, as well as a number of procedural requirements, including (1) allowing Plaintiffs to present evidence and contest evidence, (2) having the hearings on the record in open court, and (3) maintaining and making the records available for review;

Three weeks later, the Plaintiffs moved for a preliminary injunction, and shortly after all Defendants moved to dismiss the case. The Court has not yet ruled on either motion.

Sara Stearns - 03/31/2019


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
General
Bail/Bond
Fines/Fees/Bail/Bond
Poverty/homelessness
Plaintiff Type
Private Plaintiff
Causes of Action 42 U.S.C. § 1983
Declaratory Judgment Act, 28 U.S.C. § 2201
Defendant(s) All judges in the 22nd Judicial Circuit Court of Missouri
City of St. Louis
Plaintiff Description Arrestees detained St. Louis
Indexed Lawyer Organizations Advancement Project
ArchCity Defenders
Civil Rights Corps
Class action status sought Yes
Class action status granted Pending
Filed Pro Se No
Prevailing Party None Yet / None
Public Int. Lawyer Yes
Nature of Relief None yet
Source of Relief None yet
Filing Year 2019
Case Ongoing Yes
Case Listing CJ-MO-0017 : Eldridge v. City of St. John (State Court)
Docket(s)
4:19-cv-00112 (E.D. Mo.)
CJ-MO-0023-9000.pdf | Detail
Date: 04/03/2019
Source: PACER [Public Access to Court Electronic Records]
General Documents
Class Action Complaint [ECF# 1]
CJ-MO-0023-0001.pdf | Detail
Date: 01/28/2019
Source: PACER [Public Access to Court Electronic Records]
Stipulation of the Parties [ECF# 19]
CJ-MO-0023-0002.pdf | Detail
Date: 01/30/2019
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Fleissig, Audrey Goldstein (E.D. Mo.) show/hide docs
CJ-MO-0023-9000
Plaintiff's Lawyers Atri, Sima (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Friedman, Robert D. (District of Columbia) show/hide docs
CJ-MO-0023-0002 | CJ-MO-0023-9000
Harvey, Thomas B. (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Karakatsanis, Alec (District of Columbia) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Kutnik-Bauder, Jacqueline Marie (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Langum, Jacki J. (Missouri) show/hide docs
CJ-MO-0023-9000
McCord, Mary B. (District of Columbia) show/hide docs
CJ-MO-0023-9000
Strode, Blake Alexander (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Voss, Michael-John (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Waldron, John McCann (Missouri) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Wayne, Seth (District of Columbia) show/hide docs
CJ-MO-0023-0001 | CJ-MO-0023-0002 | CJ-MO-0023-9000
Defendant's Lawyers Albus, Thomas C. (Missouri) show/hide docs
CJ-MO-0023-0002 | CJ-MO-0023-9000
Bruyns, Megan Kathleen G. (Missouri) show/hide docs
CJ-MO-0023-9000
Dierker, Robert H. Jr. (Missouri) show/hide docs
CJ-MO-0023-0002 | CJ-MO-0023-9000
Isaacson, Robert J. (Missouri) show/hide docs
CJ-MO-0023-9000
Pritchett, Michael (Missouri) show/hide docs
CJ-MO-0023-9000
Reed, Peter T. (Missouri) show/hide docs
CJ-MO-0023-9000
Sauer, Dean John (Missouri) show/hide docs
CJ-MO-0023-9000
Shull, Charles D. (Missouri) show/hide docs
CJ-MO-0023-9000

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