Dixon v. City of St. Louis, No. 19-2251 (8th Cir. 2020)
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Plaintiffs, a group of pretrial arrestees who were detained in St. Louis jails, filed a 42 U.S.C. 1983 action, challenging the constitutionality of the procedures by which defendants, state and city officials, set money bail.
The Eighth Circuit reversed the district court's grant of plaintiffs' motion for class certification and entry of a preliminary injunction enjoining the enforcement of any monetary condition of release resulting in detention. In this case, the district court resorted to the extraordinary remedy of injunctive relief without adequately considering the new rules and their implementation. The district court abused its discretion by interjecting the power of the federal government into the Missouri Supreme Court's attempt to police its own lower courts, without contemplating what this would mean for federal-state relations. On remand, the district court should consider the effect of the rule changes on the question of whether a preliminary injunction served the public interest in comity between the state and federal judiciaries, as well as the necessity of an injunction.
Court Description: [Erickson, Author, with Melloy and Kobes, Circuit Judges] Civil case - Injunctions. In entering a preliminary injunction regarding bail practices in the City of St. Louis, the district court failed to give adequate consideration to the effect of Missouri Supreme Court rule changes in determining whether the issuance of the injunction served the public interest in comity between state and federal judiciaries; preliminary injunction vacated and the case remanded for further proceedings consistent with the opinion. [ February 27, 2020 ]
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