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Edwards v. Cofield

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

August 28, 2018

KANDACE KAY EDWARDS, Plaintiff,
v.
DAVID COFIELD, et al., Defendants.

          MEMORANDUM OPINION AND ORDER

          W. KEITH WATKINS CHIEF UNITED STATES DISTRICT JUDGE

         In its March 21, 2018, Memorandum Opinion and Order (Doc. # 97), the court denied both Plaintiff's motion for a preliminary injunction (Doc. # 4) and Defendants' motion to dismiss for lack of subject-matter jurisdiction (Doc. # 67). Before the court is Plaintiff's Motion for Reconsideration (Doc. # 99) of the denial of her motion for a preliminary injunction. The Motion for Reconsideration is due to be denied.

         I. STANDARD OF REVIEW

         A district court has “plenary power” over its interlocutory orders. Toole v. Baxter Healthcare Corp., 235 F.3d 1307, 1315 (11th Cir. 2000) (citation omitted). When reviewing an interlocutory decision, “the district court is not bound by the strict standards for altering or amending a judgment encompassed in Federal Rules of Civil Procedure 59(e) and 60(b).” Fye v. Okla. Corp. Comm'n, 516 F.3d 1217, 1223 n.2 (10th Cir. 2008). So a district court may reconsider an interlocutory ruling “for any reason it deems sufficient.” Canaday v. Household Retail Servs., Inc., 119 F.Supp.2d 1258, 1260 (M.D. Ala. 2000).

         Because the motion for reconsideration concerns the ruling on Plaintiff's motion for a preliminary injunction, the former is properly evaluated under the preliminary injunction standard. The Memorandum Opinion and Order outlined the preliminary injunction standard. (Doc. # 97, at 13-14.)

         II. DISCUSSION

         A. The court will not reconsider its denial of Plaintiff's motion for a preliminary injunction with respect to her first claim because rational-basis review is sufficient and because the new standing bond order survives rational-basis review.

         Plaintiff argues that the court erred when it did not apply “heightened scrutiny” to her Fourteenth Amendment claim in Count One. But under the Eleventh Circuit's recent opinion in Walker v. City of Calhoun, __ F.3d __, 2018 WL 4000252 (11th Cir. Aug. 22, 2018), the new standing bond order need only pass rational-basis review. The new standing bond order survives that level of scrutiny.

         1. Rational-basis review is the appropriate level of scrutiny.

         In Count One, Plaintiff challenges a wealth-based classification. According to Plaintiff, the new standing bond order divides arrestees into two classes. The first class - which, according to Plaintiff, is the class against which the new standing bond order discriminates - consists of arrestees detained until a bond hearing because they are unable to post a secured money bond in the amount listed in the bond schedule. The second class consists of arrestees who are able to post a secured money bond in the amount listed in the bond schedule and can obtain their release upon posting.

         Although wealth-based classifications are generally subject to rational-basis review, Plaintiff asserts that this wealth-based classification is subject to “heightened scrutiny” based on the U.S. Supreme Court's opinion in San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 17 (1973). In Rodriguez, the Court observed that it had subjected wealth-based classifications to heightened scrutiny when “the class discriminated against” met two criteria: (1) “because of their impecunity they were completely unable to pay for some desired benefit”; and (2) “as a consequence, they sustained an absolute deprivation of a meaningful opportunity to enjoy that benefit.” Id. at 20; see Id. at 18-23.

         Plaintiff's class of arrestees who cannot post a secured money bond meets the first Rodriguez criterion. By definition, those arrestees are “completely unable to pay” for any amount of pretrial release. Id. at 20. But as the Eleventh Circuit explained in Walker, indigent arrestees (such as Plaintiff) do not suffer an “absolute deprivation” of pretrial release. 2018 WL 4000252, at *10. “Rather, they must merely wait some appropriate amount of time to receive the same [pretrial release] as the more affluent. . . . Such scheme does not trigger heightened scrutiny under the Supreme Court's equal protection jurisprudence.” Id.

         2. The new standing bond order survives rational-basis review.

         Because Plaintiff's arguments were premised on the application of “heightened scrutiny, ” she has (understandably) failed to show that the new standing bond order's wealth-based classification fails under rational-basis review. She did cite one case that involved rational-basis ...


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