On December 16, 1996, an inmate at the Holmes County Jail in Ohio filed a lawsuit under 42 U.S.C. § 1983 against the representatives of the jail and the Holmes County Court in the U.S. District Court for the Northern District of Ohio. The plaintiff asked the district court for declaratory and injunctive relief, as well as damages, alleging that his constitutional rights had been violated through a denial of due process and equal protection of the court system during sentencing. The specific complaint concerned the incarceration of indigent defendants who can not afford to pay court fines.

Eventually, the parties agreed to a partial stipulation of settlement, which disposed of several issues in the case. On June 30, 2000, the U.S. District Court for the District of Ohio (Judge David D. Dowd, Jr.) accept the partial stipulation of settlement and dismissed all other motions in the case. The plaintiff filed a renewed motion for class certification, which was rejected by the court (Judge Dowd) on September 26, 2000.

On November 9, 2000, the district court closed the case. The plaintiff appealed.

On September 18, 2002, the U.S. Court of Appeals for the Sixth Circuit (Judge Arthur J. Tarnow) partially affirmed and partially reversed the district court's dismissal of the remaining claims. Alkire v. Irving, 305 F.3d 456 (6th Cir. 2002). This opinion was subsequently withdrawn by the court.

On June 2, 2003, the Sixth Circuit (Judge Tarnow) issued a second opinion, partially affirming and partially reversing the district court. The opinion held: (1) remand was necessary to determine whether county court was entitled to sovereign immunity; (2) genuine issue of material fact existed as to whether plaintiff's Fourth Amendment rights were violated; (3) genuine issue of fact existed as to whether plaintiff's constitutional rights were violated by civil debt-related incarceration; (4) remand was required to determine whether county deprived plaintiff of his constitutional rights when it incarcerated him for failure to pay fines and court costs without any inquiry into his ability to pay; and (5) plaintiff had no due process or equal protection rights to receive dollar amount credit toward fines and costs for jail time served. Alkire v. Irving, 330 F.3d 802 (6th Cir. 2003).

On September 25, 2003, the district court (Judge Dowd) dismissed the defendants Judge Jane Irving and Holmes County Court from the case. The court also dismissed the claims for damages set forth in the second through sixth claims for relief, ruling that the only question remaining for trial was the question of whether defendant Holmes County had unconstitutionally detained the plaintiff without a prompt probable cause hearing.

On October 10, 2003, the parties settled the case and agreed to settle the issue of attorney fees through mediation. On October 14, 2003, the district court (Judge Dowd) dismissed the case with prejudice. The attorney fees were settled shortly thereafter, and on July 20, 2004, the district court (Judge Dowd) entered an order of satisfaction of judgment.

Kristen Sagar - 10/20/2006


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