Case 2:24-cv-02540 Document 1 Filed 07/31/24 Page 1 of 14 PageID 1

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TENNESSEE

Just City, Inc.,

Plaintiff,

v.

Floyd Bonner Jr.,

Shelby County Sheriff;

Bill Anderson Jr.,

Presiding Shelby County General
Sessions Criminal Court Judge; and
Case No. 24-cv-2540
John Marshall, Robert Barber, Rhonda
Harris, Kevin Reed, Christopher Ingram,
Shayla Purifoy, Ross Sampson, Serena Gray,
Terita Hewlett, Mischelle Best, Kenya Smith,
Zayid Saleem, Kathy Kirk Johnson, Leslie
Mozingo,
Shelby County Judicial
Commissioners,

in their official capacities,

Defendants.

COMPLAINT

1. This action challenges Tennessee’s unprecedented new law, HB 1719, which

prohibits judges from considering an arrestee’s ability to pay when setting bail. This law is

contrary to decades of constitutional precedent requiring courts to consider ability to pay as a

matter of fundamental fairness. The law mandates arbitrariness by requiring judges to ignore the

consequences of their bail orders and disregard whether arrestees will be released or detained.
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No other state in the nation prohibits judges from considering ability to pay when setting bail; in

fact, the majority of states explicitly require their judges to consider ability to pay.

2. The purpose of this law was to target reforms to Shelby County’s bail system. In

2023, Shelby County undertook reforms to end the decades-long practice of setting bail without

considering ability to pay. This practice had resulted in widespread unnecessary detention of

people who could not afford their bail amounts, but who would otherwise return to court and live

peacefully in their communities if released.

3. Shelby County’s bail reforms were memorialized in a binding agreement between

local advocates, including Plaintiff Just City; and Shelby County officials, including Defendants

Shelby County Sheriff and the Presiding General Sessions Criminal Court Judge. Among other

changes, the agreement requires Judicial Commissioners to use the output of an ability-to-pay

calculator to evaluate arrestees’ financial information when setting bail. Under the agreement,

Judicial Commissioners must set affordable bail if they intend to release an arrestee, or set

unaffordable bail if they intend to detain an arrestee. The Judicial Commissioners undertook

these new practices beginning February 15, 2023.

4. Fourteen months later, on May 1, 2024, Tennessee enacted a new law prohibiting

judges from considering an arrestee’s “ability to pay.” The legislation was a direct attack on the

reforms implemented in Shelby County: the bill’s sponsors specifically referenced Shelby

County’s ability-to-pay calculator in the legislative record. They also made baseless allegations

that the reforms were linked to higher crime rates, yet disregarded data showing a lower rate of

re-arrests following implementation of the reforms.

5. Because of the new law, Shelby County officials abandoned their constitutional

obligations and the terms of the agreement. The Presiding General Sessions Criminal Court

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Judge instructed court administrators to stop using the ability-to-pay calculator to evaluate

arrestees’ financial information and change local bail processes to remove any reference to

ability to pay. Judicial Commissioners stopped considering arrestees’ ability to pay when setting

bail. The Shelby County Sheriff enforces the resulting unconstitutional bail orders and detains

arrestees who are unable to pay for their release.

6. Just City brings this action to vindicate Shelby County arrestees’ constitutional

rights.

JURISDICTION AND VENUE

7. This is a civil rights action arising under 42 U.S.C. § 1983, 28 U.S.C. § 2201 et

seq., and the Fourteenth Amendment to the United States Constitution. This Court has

jurisdiction under 28 U.S.C. §§ 1331 (federal question jurisdiction) and 1343 (civil rights

jurisdiction).

8. Venue in this Court is proper under 28 U.S.C. § 1391 because Defendants are

located within the district, and a substantial part of the events giving rise to these claims occurred

and will occur in this district.

PARTIES

9. Plaintiff Just City is a mission-driven nonprofit organization dedicated to fighting

discrimination based on race, ethnicity, and income in Shelby County criminal proceedings. Just

City operates a charitable bail fund to advance this mission. Just City entered into a

Memorandum of Understanding with Shelby County officials on June 9, 2022 (the

“Agreement”). The Agreement’s purpose is to “ensure that every arrestee who enters the

criminal justice system in Shelby County, Tennessee receives adequate constitutional

protection.”

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10. Defendant Shelby County Sheriff operates the Shelby County Jail and enforces

bail orders issued by Shelby County Judicial Commissioners. The Sheriff is bound by the

Agreement, which prohibits detention under bail orders issued without consideration of ability to

pay. The Sheriff is sued for injunctive and declaratory relief.

11. Defendant Presiding Shelby County General Sessions Criminal Court Judge (the

“Presiding Judge”) directs court administration in Shelby County criminal proceedings and

issues binding guidelines on bail setting for the Shelby County Judicial Commissioners. The

Presiding Judge is bound by the Agreement to enact policies operationalizing reforms in the

Agreement, including consideration of ability to pay. The Presiding Judge also sets bail at

hearings held subsequent to the initial bail setting by the Judicial Commissioners. The role of

Presiding Judge rotates annually among General Sessions Criminal Court Judges; the current

Presiding Judge is Hon. Bill Anderson. The Presiding Judge is sued in his official capacity for

declaratory relief.

12. Defendant Shelby County Judicial Commissioners set bail in Shelby County

criminal proceedings. They are bound by the Agreement to evaluate ability to pay using the

assessment from Shelby County pretrial services, and to order affordable or unaffordable bail for

each arrestee based on the commissioner’s intention to release or detain. The Judicial

Commissioners are sued in their official capacities for declaratory relief.

FACTUAL ALLEGATIONS

13. HB 1719 took effect on May 1, 2024. The law prohibits consideration of ability to

pay when setting bail. The Presiding Judge and Judicial Commissioners have implemented HB

1719 by ending the prior practice of considering and determining ability to pay when setting bail,

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as required under the Agreement. The Shelby County Sheriff is enforcing bail orders issued

under this scheme by detaining people who are unable to pay for their release.

I. Shelby County Had a History of Setting Bail Without Considering Ability to Pay

14. Shelby County entered into the Agreement due to its history of failing to consider

arrestees’ ability to pay and thus unnecessarily detaining people who cannot afford to pay for

release, but who would otherwise return to court and live peacefully in their communities.

15. Tennessee statutes require that judges1 treat secured cash bail2 as a matter of last

resort. Judges can impose bail only after determining that less restrictive conditions will not

reasonably ensure the safety of the community and the appearance of the arrestee:

a. First, the judge must consider whether to release the arrestee on their

personal recognizance or subject to other conditions that do not require a payment in

exchange for release.3

b. Second, if those conditions are insufficient, the judge must set bail as a

condition of release.4 The judge must set the lowest bail amount that will reasonably

ensure the safety of the community and the appearance of the arrestee.5 In so doing, the

1
The complaint uses the term “judge” to refer to any judicial officer who sets bail, including the
Shelby County Judicial Commissioners.
2
The complaint uses the term “bail” to refer to secured bail, which requires a payment in
exchange for release. This is in contrast to unsecured bail or unsecured bond, which does not
require a payment before release, but obligates the arrestee to pay the bail amount if they fail to
appear as required.
3
Tenn. Code Ann. §§ 40-11-115 (release on recognizance or unsecured bond), 40-11-116
(release subject to additional conditions).
4
Tenn. Code Ann. § 40-11-117.
5
Tenn. Code Ann. § 40-11-118(a)(2).

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judge must consider statutory factors such as the arrestee’s community ties, prior criminal

record, alleged offense, and, critically, the arrestee’s “financial condition.”6

16. Historically, Shelby County set bail through this process without considering

arrestees’ ability to pay. In April 2021, prior to the Agreement, a court-appointed jail monitor

reported: “When bail is considered in Shelby County, the judicial commissioner setting bail does

not take into account the economic ability or inability of the detainee to post bond.” First Covid-

19 Follow Up Inspection of the Shelby County Men’s Jail at 30, Busby v. Bonner, No. 20-cv-

2359 (W.D. Tenn May 19, 2021), ECF No. 216-5. This practice, the monitor noted, resulted in

the unnecessary detention of people who “simply cannot afford even a minimal bail.” Id. Such

detention was “not necessary to ensure future court appearances or to protect public safety.” Id.

People unable to afford bail were routinely detained for weeks or longer without receiving a bail

hearing with counsel present.

17. People who could not afford bail were detained in the Shelby County Jail under

inhumane conditions. See, e.g., Busby v. Bonner, No. 2:20-CV-2359-SHL-ATC, 2021 WL

4127775, at *1 (W.D. Tenn. Jan. 28, 2021) (preliminarily approving settlement requiring

monitoring of jail’s management of COVID-19 crisis).

II. The Agreement Requires Shelby County to Consider Ability to Pay

18. Just City warned Shelby County officials that the County would face a lawsuit if

officials did not reform their unconstitutional bail practices. In December 2021, Just City and

other advocates sent a demand letter to Shelby County’s General Sessions Criminal Court

Judges, Chief Judicial Commissioner, and Sheriff, along with the District Attorney, Public

Defender, Pretrial Services Office, the Chairman of the Shelby County Board of Commissioners,

6
Tenn. Code Ann. §§ 40-11-118(b)(2).

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and County Mayor (“Shelby County stakeholders”). The letter detailed the findings of the

advocates’ eighteen-month investigation and demanded remedies including, most importantly,

consideration of arrestees’ ability to pay when setting bail.

19. The advocates and Shelby County stakeholders met several times to negotiate

reforms, culminating in the Agreement executed on June 9, 2022. The purpose of the Agreement

was to protect the constitutional rights of every arrestee who enters the criminal justice system in

Shelby County from arrest through the decision to release or detain pending trial. A critical

component of the Agreement was creation of procedures to assess arrestees’ ability to pay bail.

The goal was to prevent arrestees from being jailed solely because of their poverty.

20. The Agreement required, in relevant part, the following procedures for bail setting

and pretrial detention:

a. Immediately after arrest, pretrial services interviews arrestees about their

finances to evaluate their ability to pay bail. Pretrial services provides that evaluation to

the judicial commissioner.

b. After the ability-to-pay evaluation and within 12 hours of arrest, a judicial

commissioner conducts an ex parte initial screening to determine whether to release or

detain the arrestee. The judicial commissioner follows the two-step process under

Tennessee law: first, the judicial commissioner considers whether to release the arrestee

on their own recognizance or other conditions that do not require a payment in exchange

for release. Second, only after determining that other conditions will not reasonably

ensure the safety of the community and the appearance of the arrestee, the judicial

commissioner may set a bail amount. The bail amount must be affordable, and thus allow

for release, if affordable bail would reasonably ensure the safety of the community and

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the appearance of the arrestee. The bail amount may be unaffordable, and thus detain the

arrestee, only if no other combination of release conditions would not reasonably ensure

the safety of the community and the appearance of the arrestee.

c. A decision to set unaffordable bail triggers additional procedures to

protect the arrestee’s liberty interests. Arrestees detained under an unaffordable bail

amount receive a subsequent, robust bail hearing with defense counsel present, at which

the prosecutor bears the burden of justifying the unaffordable bail order.

21. The Agreement recognized that an unaffordable bail was a de facto detention

order. For that reason, it required judges to consider ability to pay before setting bail and provide

their reasoning for imposing an unaffordable detention order—lest an arrestee be subject to

unnecessary wealth-based detention in violation of the Constitution.

22. The Presiding Judge, together with other General Sessions Criminal Court Judges,

implemented these changes through an administrative Standing Bail Order issued on August 15,

2022. As contemplated by the Agreement, the advocates and Shelby County stakeholders also

developed an ability-to-pay calculator and drafted bail forms that required judges to input the

amount that an arrestee was able to pay, consider that amount before setting bail, and state

whether they intended to release the individual on affordable bail or detain them on unaffordable

bail. The ability-to-pay calculator and bail forms were implemented at the direction of the

Presiding Judge.

23. After these changes went into effect in early 2023, the Judicial Commissioners

considered arrestees’ ability to pay as a standard practice. This practice was subject to immediate

political attack. During the 2024 legislative session, Tennessee legislators targeted the ability-to-

pay calculator in Shelby County, and the resulting debates revealed a fundamental

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misunderstanding of Shelby County practices under the Agreement and Tennessee’s pretrial

release statutes.

24. For example, one of the bill’s sponsors claimed that HB 1719 was intended to

address a “revolving door of criminals going in and out of our judicial system,” and “focus on

the danger that person poses to the community” to prevent “tragic consequences of allowing

people into the community based on their ability to pay.”

25. These statements directly contradicted data about how the Agreement operated on

the ground. Fewer people were rearrested under the Agreement: only 7% of people released

pretrial were rearrested, as compared to 11% of people released before the Agreement was

implemented. Lead Judicial Commissioner John Marshall stated: “I think the statistics bear out

that it is not a revolving door,” and that he “did not see a pattern of someone committing a

violent crime—like a carjacking—and bonding out and then committing another carjacking.”

26. Many Shelby County residents testified about this data during legislative hearings

and tried to correct misperceptions about the Agreement. Legislators did not heed their

explanations. Instead, multiple legislators persisted in their misunderstanding, or willful

misrepresentation, that use of the ability-to-pay calculator prevented judges from giving

appropriate weight to other bail-setting factors required under Tennessee law. One representative

said: “To say that a person’s ability to pay should be the trump card . . . ignores all of the statutes

that talks about length of criminal history, seriousness of offense, and length in the community.”

27. None of the proponents of the bill explained how judges could consider the

arrestee’s “financial condition” if they were forbidden from considering the arrestee’s “ability to

pay.”

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28. HB 1719 was ultimately enacted on May 1, 2024, as 2024 Tenn. Pub. Acts Ch.

869.

29. The Act amended Tenn. Code Ann. § 40-11-118(a)(2) to preserve the existing

mandate that judges consider an arrestee’s “financial condition,” but add the phrase: “provided,

that, the defendant’s ability to pay shall not be considered.”

III. Shelby County Stopped Considering Ability to Pay After Passage of HB 1719

30. The impact of HB 1719 has been swift and devastating.

31. After the General Assembly passed HB 1719 and before the Governor signed it

into law, Just City urged the Defendants, through the Shelby County Attorney, to continue

following constitutional requirements and the Agreement.

32. Instead, days before HB 1719 went into effect, the General Sessions Judges

convened an administrative meeting to make decisions about the law’s implementation.

33. Shortly after the meeting, pretrial services stopped administering the ability-to-

pay calculator. The Judicial Commissioners started using new bail forms that did not reference

ability to pay bail, which the County Attorney’s Office later reported they had drafted at the

General Sessions Judges’ direction. The Judicial Commissioners stopped considering ability to

pay when setting bail. The Sheriff began enforcing the resulting unconstitutional bail orders to

detain arrestees who are unable to pay for their release. This process, which persists today,

results in widespread unconstitutional wealth-based detention.

34. Plaintiff Just City has advocated to reform Shelby County’s pretrial detention

practices for years. In an effort to reduce the harm caused by Shelby County’s pretrial detention

practices, Just City launched a charitable bail fund in 2017. The purpose of the bail fund is to

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post bail for as many people as possible who are referred by the Shelby County Public

Defender’s Office and who have been determined to be indigent by a Shelby County judge.

35. Just City pays the full cash bail amount to the clerk for indigent arrestees who

cannot afford to do so. After an indigent arrestee for whom Just City pays cash bail attends

required court appearances and their case concludes, Just City receives a full refund of the bail

amount. Just City then recycles this refund to pay bail for other qualifying arrestees. The bail

fund has been revolving in this manner for more than seven years, and Just City has paid

$3,000,000.00 in cash bail for more than 1,700 people since it launched the bail fund.

36. HB 1719 has inhibited Just City’s mission by limiting the number of people Just

City can serve. Without consideration of ability to pay, bail amounts for indigent arrestees

referred to Just City have increased significantly. These higher bail amounts limit the total

number of clients Just City can serve with its limited bail fund.

37. In addition, HB 1719 has inhibited Just City’s mission by prohibiting judges from

considering the possibility of Just City’s contribution to the arrestee’s ability to pay. Prior to HB

1719, judges regularly set bail amounts based on the understanding of what the arrestee would be

able to pay with assistance from Just City. In some marginal cases, judges have ordered slightly

lower bail amounts to ensure that Just City could pay for release. HB 1719 forbids judges from

considering the availability of Just City’s assistance in these marginal cases, resulting in

detention for arrestees whom judges would otherwise release by setting bail amounts that

arrestees could afford with Just City’s help.

38. As a mission-driven organization with years of experience advocating for

arrestees in the Shelby County criminal system, Just City has a close relationship with Shelby

County arrestees and can effectively advocate for their rights. Individual arrestees face

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numerous obstacles to bringing claims under Section 1983. Arrestees have extremely limited

resources, and the vast majority cannot afford to pay even minimal bail amounts, let alone

litigate a federal lawsuit. Arrestees are also hindered from vindicating their rights by the high

likelihood that their claims will become moot before they are decided, because their criminal

cases resolve and their pretrial detention will end.

CLAIMS FOR RELIEF

Under 42 U.S.C. § 1983

39. Just City brings each claim against Defendant Shelby County Sheriff for

injunctive and declaratory relief, and against Defendant Presiding Shelby County General

Sessions Criminal Court Judge and Shelby County Judicial Commissioners for declaratory relief.

This case raises an actual and substantial dispute between the parties that warrants declaratory

relief under 28 U.S.C. § 2201.

Count One: Fundamentally Unfair Procedures for a Bail Hearing

In Violation of the Fourteenth Amendment

40. Just City incorporates the foregoing allegations.

41. HB 1719 prohibits judges from considering an arrestee’s ability to pay when

issuing bail orders and setting the amount of bail an arrestee must pay to be released.

42. Without considering ability to pay, Judicial Commissioners issue bail orders that

require pretrial detention for any arrestee unable to afford their bail amount.

43. Failure to consider ability to pay results in widespread pretrial detention of people

who cannot afford their bail amounts, and who do not need to be detained to reasonably ensure

the safety of the community and the appearance of the arrestee as required.

44. The government has no legitimate interest in preventing judges from considering

ability to pay when setting bail.

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45. Prohibiting consideration of ability to pay when setting bail is a fundamentally

unfair procedure for the deprivation of an arrestee’s liberty pending trial.

46. The statutory prohibition on consideration of an arrestee’s ability to pay when

setting bail violates the Due Process Clause of the Fourteenth Amendment.

Count Two: Discriminatory Wealth-Based Detention

In Violation of the Fourteenth Amendment

47. Just City incorporates the foregoing allegations.

48. Pursuant to HB 1719, Judicial Commissioners set bail without inquiring into or

determining arrestees’ ability to pay their bail amounts. Arrestees who cannot afford their bail

amounts are detained under the Judicial Commissioners’ orders.

49. Detention under an unaffordable bail order, without any inquiry into or

determination of ability to pay or meaningful consideration of alternatives, is discriminatory

wealth-based detention in violation of the Due Process and Equal Protection Clauses of the

Fourteenth Amendment.

RELIEF REQUESTED

Just City requests that this Court issue the following relief:

1. A declaration that HB 1719 violates the Fourteenth Amendment right to due

process and right against wealth-based detention;

2. An order permanently enjoining the Shelby County Sheriff from enforcing secured

bail orders that are issued without a determination of ability to pay against arrestees who are unable

to pay for release;

3. An order granting reasonable attorneys’ fees and costs under 42 U.S.C. § 1988; and

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4. Any other relief this Court deems just and proper.

Respectfully Submitted,

/s/ Trisha Trigilio

Trisha Trigilio Stella Yarbrough
Tex. Bar No. 24075179 American Civil Liberties Union
Julian Clark Foundation of Tennessee
Ashika Verriest P.O. Box 120160
Brandon Buskey Nashville, TN 37212
American Civil Liberties Union Foundation (615) 320-7142
Criminal Law Reform Project syarbrough@aclu-tn.org
125 Broad Street, 17th Floor
New York, NY 10004
(347) 302-2797
trishat@aclu.org

Craig S. Waldman
David Elbaum
Jared Quigley
Simpson Thacher & Bartlett LLP
425 Lexington Avenue
New York, NY 10017
(212) 455-2000
cwaldman@stblaw.com
david.elbaum@stblaw.com
jared.quigley@stblaw.com

Attorneys for Plaintiff

Pro hac vice motions forthcoming

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JS 44 (Rev. 0 ) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Just City, Inc. Floyd Bonner Jr., Shelby County Sheriff,
et al.
(b) County of Residence of First Listed Plaintiff Shelby County, TN County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
See attachment

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 861 HIA (1395ff) 485 Telephone Consumer
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 862 Black Lung (923) Protection Act
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management 863 DIWC/DIWW (405(g)) 490 Cable/Sat TV
195 Contract Product Liability 360 Other Personal Property Damage Relations 864 SSID Title XVI 850 Securities/Commodities/
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 865 RSI (405(g)) Exchange
362 Personal Injury - Product Liability 751 Family and Medical 890 Other Statutory Actions
Medical Malpractice Leave Act 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation FEDERAL TAX SUITS 893 Environmental Matters
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 870 Taxes (U.S. Plaintiff 895 Freedom of Information
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act or Defendant) Act
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRS—Third Party 896 Arbitration
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 899 Administrative Procedure
245 Tort Product Liability Accommodations 530 General Act/Review or Appeal of
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Agency Decision
Employment Other: 462 Naturalization Application 950 Constitutionality of
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration State Statutes
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity) :
42 U.S.C. Sec. 1983; 28 U.S.C. Sec. 2201
VI. CAUSE OF ACTION Brief description of cause:
Violation of the Fourteenth Amendment
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
07/31/2024
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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