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Case: 61CO1:24-cr-15875 Document #: 53 Filed: 05/10/2024 Page 1 of 6
IN THE COUNTY COURT OF RANKIN COUNTY, MISSISSIPPI
STATE OF MISSISSIPPI PLAINTIFF
VS. CAUSE NO. 24-15875
CARLY MADISON GREGG DEFENDANT
________________________________________________________________
MOTION TO REDUCE BOND
________________________________________________________________
COMES NOW the Defendant, Carly Madison Gregg, by and through her
counsel of record, and files this her Motion to Reduce Bond (“Motion”) pursuant to
Rule 8 of the Mississippi Rules of Criminal Procedure, and in support thereof would
respectfully show unto this Honorable Court the following facts and matters, to-wit:
1.
Carly is currently 15 years old. Her bond is currently set at One Million
Dollars ($1,000,000.00). Carly has not been indicted.
2.
Carly was arrested and taken into custody on Tuesday, March 19th, 2024,
after she flagged down a patrol car and peacefully turned herself over to law
enforcement.
3.
Carly has no prior criminal record whatsoever, nor does she have a history
of violence.
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4.
To the contrary, Carly was an honor roll student and student of the year at
Northwest Rankin Highschool prior to her arrest.
5.
Carly has no income, no bank account, and no assets.
6.
Carly does not have a driver’s license, a car, or a passport.
7.
Carly does not possess the financial means or resources to raise the funds
required to pay her current bond. Carly’s current bond is excessively high and set
at an unreasonable amount. (See Lee v. Lawson, 375 So. 2d 1019, 1024 (Miss.
1979)).
8.
The State charged Carly as an adult. Therefore, Carly has been detained in
solitary confinement and not allowed visitors (with the sole exception of her
attorneys), or the ability to speak with anyone for twenty-three (23) hours a day.
Carly has been isolated under these conditions for nearly two months as of the
date of the filing of this Motion. This extreme confinement and isolation is
deteriorating Carly’s mental state and is punitive.
9.
Carly has been detained in solitary confinement for nearly two months
without being indicted.
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10.
Dr. James O’Brien has been retained to conduct a psych evaluation and
testing on Carly, but this evaluation and testing cannot be done while Carly is in
jail.
11.
Carly has been charged as an adult, but adults charged with the same crime
as Carly are not being held in the same form of extreme confinement.
12.
Children who are the same age as Carly and in the same grade as Carly
and who attend the same school as Carly have been charged with the same crime
as Carly but have received much lower bonds. Please see attached as Exhibit “A”
examples of much lower bond set for children who face the same charges in the
tri-county area.
13.
Both the living victim and the family members of the deceased victim support
Carly’s bond being reduced.
14.
Carly is not a danger to herself or the community. There is no risk of Carly
fleeing the jurisdiction, and she has already demonstrated her willingness to turn
herself in to law enforcement.
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15.
Carly has lived in Rankin County for years. Her family members, school, and
friends all reside in Rankin County and the surrounding area.
16.
Alternative options are available to restrict Carly’s movements, protect the
community, and ensure Carly’s Courtroom appearance. Such alternative options
would also allow Carly access to necessary mental health care and enable her to
continue attending school online until her indictment and/or trial while releasing
Carly from solitary confinement on an unsecured bond.
17.
Carly cannot possibly pay her initial bond amount. Bond is not meant to force
a defendant to rot in jail until his or her case can be heard. Refusing to reduce
Carly’s bond effectively denies her the right to a bond and leaves her in pre-trial
detention even though she is not a flight risk or a risk to the public, which violates
the 8th Amendment of the United States Constitution. (18 U.S.C. § 3142 (2022),
also see U.S. v. Szott, 768 F.2d 159 (7th Cir. 1985)).
18.
Carly has the benefit of being deemed innocent until proven guilty.
WHEREFORE, PREMISIS CONSIDERED, Carly Madison Gregg,
respectfully requests that this Court will reduce her initial bond to a reasonable
amount and to give Carly an unsecured bond based on her circumstances. Carly
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requests such other relief, either general or specific, to which she may show herself
to be entitled in a Court of law.
Respectfully Submitted, this the 10th day of May, 2024.
/s:/ Caleb Coleman
CALEB COLEMAN, MSB #106463
COLEMAN | TODD LAW FIRM, PLLC
200 E. Government Street
Post Office Box 1645
Brandon, Mississippi 39042
Telephone: (601) 824-5040
Email: caleb@colemantoddlaw.com
Attorney for Carly Madison Gregg
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CERTIFICATE OF SERVICE
I, Caleb Coleman, counsel for Defendant, CARLY MADISON GREGG, in the
above-referenced matter, do hereby certify that on this the 10th day of May, 2024, a true
and correct copy of the foregoing Motion to Reduce Bond was served on the following:
Kathryn White Newman, Esq. [ ] Via U.S. Mail, regular delivery
Assistant District Attorney [ ] Via Hand Delivery
P.O. Box 68 [ ] Via Facsimile
Brandon, MS 39043 [ ] Via Email
Tel: (601) 825-1472 [ x ] Via MEC system
Email: knewman@rankincounty.org
A.D.A. for the 20th Circuit Court District
/s:/ Caleb Coleman
CALEB COLEMAN, MSB #106463
COLEMAN | TODD LAW FIRM, PLLC
200 E. Government Street
Post Office Box 1645
Brandon, Mississippi 39042
Telephone: (601) 824-5040
Email: caleb@colemantoddlaw.com
Attorney for Carly Madison Gregg
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