In its opinion Wednesday, the Fifth Circuit said that the case, which challenged the bail practices of a Louisiana parish for requiring money bail for pretrial detainees who can't afford it, should be remanded to district court and dismissed because of a different decision the appeals court made in March. That decision, delivered by the Fifth Circuit while an appeal of the bail practice case was pending, said that lower federal courts can't rule on lawsuits that challenge local bail practices while potential state constitutional challenges still exist, which, in this case, they do.
"While the appeal was pending, this court en banc held that district courts must abstain from suits contesting a local jurisdiction's bail practices when there is an opportunity in state court to present constitutional challenges to bail," the appeals court wrote in its appeal. "The parties agree there exists an opportunity here. Therefore, we remand for the district court to dismiss the case."
In its Wednesday ruling, the court referred to its March decision, which highlighted how federal courts must decline to decide cases that stem from a state criminal defendant's claims when the federal case would interfere with an "ongoing state judicial proceeding," along with two other factors, including whether potential state constitutional challenges to the practice exist.
In the original case, plaintiff Edward Little had sued several Lafayette Parish officials alleging he was held in jail with no chance to show that he couldn't afford the $3,000 bail. Filing the case as a class action, Little argued that the practice constituted a constitutional violation, but after a one-day bench trial in which the officials argued there actually was a procedure to consider that factor, the district court denied relief to Little.
After requesting briefing from the parties about how the appeals court's March decision should impact the case, it was clear that the federal lawsuit should be dismissed, the court wrote.
"The Plaintiffs concede, and the Defendants insist, that it is necessary for the court to abstain and dismiss the suit," the court wrote, going on to analyze if its March decision should apply and ultimately agreeing that it should.
In its analysis, the Fifth Circuit noted that the U.S. District Court for the Western District of Louisiana, which originally heard the case in 2020, hadn't considered whether the new case law from its March decision would impact the case. Since the lower court hadn't done that, the appeals court took charge.
It ultimately decided that all three factors from its March ruling applied to Little's case. Beyond the fact that a federal decision would interfere with an ongoing state proceeding, it also determined that the state has an important interest in regulating the subject matter of the claim and that the plaintiff has an adequate opportunity in the state proceedings to raise a constitutional challenge.
The plaintiffs are represented by Alec Karakatsanis of Civil Rights Corps and Daniel S. Volchok of WilmerHale.
The defendants are represented by Patrick B. McIntire of Oats and Marino LLP.
The case is Little v. Doguet et al., case number 20-30159, in the U.S. Court of Appeals for the Fifth Circuit.
--Editing by Andrew Cohen.
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