BRADLEY PATTON, on behalf of himself and others similarly situated v. MIKE FITZHUGH, in his official capacity as Sheriff of Rutherford County, Tennessee; MELISSA HARRELL, in her official capacity as Clerk of the Rutherford County Circuit and General Sessions Courts; JAMES TURNER, BARRY R. TIDWELL, and HOWARD WILSON, in their official capacities as Circuit Judges for the Sixteenth Judicial District - Articles

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BRADLEY PATTON, on behalf of himself and others similarly situated v. MIKE FITZHUGH, in his official capacity as Sheriff of Rutherford County, Tennessee; MELISSA HARRELL, in her official capacity as Clerk of the Rutherford County Circuit and General Sessions Courts; JAMES TURNER, BARRY R. TIDWELL, and HOWARD WILSON, in their official capacities as Circuit Judges for the Sixteenth Judicial District

Posted by: Azya Thornton on Mar 13, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Drew Justice, JUSTICE LAW OFFICE, Murfreesboro, Tennessee, for Appellant.

Attorneys 2: ON BRIEF: Nick Christiansen, HUDSON, REED & CHRISTIANSEN, PLLC, Murfreesboro, Tennessee, for the Rutherford County Appellees.

Attorneys 3: ON BRIEF: Eric W. Donica, OFFICE OF THE TENNESSEE ATTORNEY GENERAL, Nashville, Tennessee, for the State Appellees.

Judge(s): MOORE, KETHLEDGE, and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Middle District of Tennessee at Nashville

KAREN NELSON MOORE, Circuit Judge. This appeal concerns issues of standing and mootness in a putative class-action suit. According to Bradley Patton, state and local officials in Rutherford County, Tennessee unconstitutionally require pre-trial detainees to prove in a hearing before the state court that any bail funds equal to or in excess of $75,000 were not derived directly or indirectly from criminal activities. On June 13, 2023, Patton requested permission to post $100,000 to cover outstanding bail. Despite having the funds ready to secure his release, Patton was not released from custody. Under Rutherford County’s local rules, Patton had to wait for the state court to schedule a hearing to determine whether the bail money was sourced from any criminal activities. Patton filed this putative class action in federal court claiming that this local rule violated his and the putative class’s due-process and Eighth Amendment rights. For the reasons that follow, we REVERSE the district court’s judgment dismissing Patton’s claims on jurisdictional grounds and REMAND for proceedings consistent with this opinion.

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