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Chapman v. City of Clanton

United States District Court, M.D. Alabama, Northern Division

April 25, 2017

CANDICE CHAPMAN, et al ., Plaintiffs,
THE CITY OF CLANTON, et al., Defendants.


          ROYCE C. LAMBERTH United States District Judge.

         This case is one of several before the Court that all contain similar allegations: that Alabama cities attempting to increase municipal budgets were running debtor's prisons and implementing policies that adversely impacted indigent residents of those cities. Currently before the Court are motions to dismiss plaintiffs' amended complaint under Federal Rule of Civil Procedure 12(b)(6). Such motions were filed by the City of Clanton, Judicial Correction Services (JCS), and CHC Companies, Inc. These motions will be granted in part and denied in part.

         Though distinct in certain ways, this case is similar to other cases pending before this Court, most notably McCullough v. City of Montgomery, 2:15-cv-463, and Carter v. City of Montgomery, 2:15-cv-555. This memorandum opinion should be read in conjunction with the opinions issued in those cases, as the issues overlap and Court will not repeat its analysis in this memorandum opinion. The memorandum opinions in those cases can be found at docket entry 131 in McCullough and docket entry 97 in Carter.

         I. Background

         Like Carter and McCullough, this case concerns the policies and practices of an Alabama City that contracted with a private probation company, JCS, which is alleged to have denied indigent defendants a host of rights.

         Specifically, they allege that the city of Clanton signed a contract with JCS that nominally allowed JCS to run probation services. JCS ran on an “offender funded” model, where they would charge people on probation set-up as well as monthly fees to remain on probation.

         When individuals were arrested for minor crimes and unable to pay fees, they were automatically placed into JCS probation and made monthly payments. If individuals were unable to pay, their fees were converted to jail time with durations tied to the amounts owed. For example, one plaintiff's fine of $1, 415 was converted into 28.3 days in jail-a rate of $50 a day. Another plaintiff was given 21.12 days.

         Plaintiffs contend this was all done without any indigency determinations being made and without access to counsel. They further argue that the entire contract between the City and JCS is unlawful.

         II. Legal Standards

         A motion to dismiss is appropriate when the complaint fails “to state a claim upon which relief can be granted.” Fed.R.Civ.P. 12(b)(6). Such a failure occurs when the complaint is so factually deficient that the plaintiff's claim for relief is not plausible on its face. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). Though facts in a complaint need not be detailed, Rule 8 “demands more than an unadorned, the-defendant-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The Court must accept all factual statements as true when deciding a Rule 12(b)(6) motion to dismiss. Id. at 678. However, conclusory legal allegations devoid of any factual support do not enjoy the same presumption of truth. Id. at 679. “Factual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. This is not a high bar however, as plaintiffs need only plead facts sufficient to “nudge[] their claims across the line from conceivable to plausible.” Id. at 547.

         III. Counts

         This case contains eleven counts. The first is for denial of due process by the City of Clanton. The second is for denial of due process by JCS. The third and fourth counts are for violations of the fourth amendment by Clanton and JCS, respectively. Counts five and six allege violations of the sixth amendment by the City and JCS. Counts seven and eight allege violations of the eighth amendment. The ninth and tenth counts are for violations of equal protection by Clanton and JCS. The final count, eleven, is for declaratory and injunctive relief against both JCS and Clanton.

         1. Violations by the City of Clanton

         The City spends the bulk of their motion to dismiss arguing that they are not responsible for the actions of JCS or any actions taken by the Clanton Municipal Court. In this way, the City's argument is incredibly similar to that made by the City of Montgomery in Carter and McCullough. Here, they argue that because the municipal court is an arm of the State, not the City, it is impossible for the City to be liable for its actions. City Mot. Dismiss 26, ECF No. 80. ...

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