Case 3:15-cv-00567-SDD-RLB Document 1 08/25/15 Page 1 of 13

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

REBECCA M. SNOW, individually and on behalf of all others similarly situated,
Plaintiffs,
v.
MARILYN M. LAMBERT, in her official capacity as Judge of Ascension Parish Court, and JEFFREY F. WILEY, in his official capacity as Ascension Parish Sheriff,
Defendants

Case No. 15-cv-00567 Complaint-Class Action

CLASS ACTION COMPLAINT Introduction
This case is about the Ascension Parish jailing some of its poorest people because they cannot pay a small amount of money. Rebecca Marie Snow was arrested on August 24, 2015, and is currently detained by Defendant Ascension Parish Sheriff Jeffrey F. Wiley because she cannot afford to pay the amount of money generically set by the secured “bail schedule” issued by Ascension Parish Court Judge Marilyn Lambert.
In Ascension Parish, most people arrested for traffic or misdemeanor offenses are released immediately upon payment of a small amount of money. The amount of the bond ranges from several hundred dollars to several thousand dollars. If a person is charged with multiple offenses, the fixed amount for each offense is added together to determine the total amount of cash required for release. Those arrestees who are too poor to afford to pay remain in jail because of their poverty for up to three days without seeing a judicial officer.

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On behalf of the many other arrestees subjected to the Defendants’ unlawful and ongoing post-arrest money-based detention scheme, the named Plaintiff challenges in this action the use of an unlawful generic offense-based “bail schedule” that operates to detain only the most impoverished misdemeanor arrestees. The Defendants’ policy has no place in modern American law.
By and through her attorneys and on behalf of herself and all others similarly situated, the named Plaintiff seeks in this civil action the vindication of her fundamental rights, injunctive relief assuring that her rights and the rights of the other Class members will not continue to be violated, and a declaration that the Defendants’ conduct is unlawful.
Nature of the Action1 1. It is the policy and practice of Defendants to refuse to release traffic and misdemeanor arrestees from jail unless they pay a generically set amount of money. That amount is between $112 and $1,169.50 for most violations. Because this sum is set generically by reference to the alleged offense of arrest, no individualized factors are considered, and anyone who cannot afford to pay is held in jail for up to three days before a judicial hearing in which they could theoretically have an individualized determination of their bail. In some cases, such as Ms. Snow’s, a defendant is not allowed by the judicial officer to seek an individualized determination of bail. Plaintiff seeks declaratory and injunctive relief.
1 Plaintiff makes the allegations in this Complaint based on personal knowledge as to matters in which she has had personal involvement and on information and belief as to all other matters.
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Jurisdiction and Venue 2. This is a civil rights action arising under 42 U.S.C. § 1983 and 28 U.S.C. § 2201, et seq., and the Fourteenth Amendment to the United States Constitution. This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1343. 3. Venue in this Court is proper pursuant to 28 U.S.C. § 1391.
Parties 4. Named Plaintiff Rebecca M. Snow is a 33-year-old woman living in the Gonzales, Louisiana. She is the mother of two children. She represents herself as an individual and a Class of similarly situated people all subject to the Defendants’ post-arrest money-based detention scheme. 5. Defendant Marilyn Lambert is the Judge of Ascension Parish Court, organized under the laws of the State of Louisiana, La. R.S. §§ 13:2563.1–2563.17. Judge Lambert has the authority to “admit to bail and discharge” defendants in all but capital cases, La. R.S. § 13:2563.7. As Judge of Ascension Parish Court, Defendant Lambert’s jurisdiction extends to State misdemeanors and the violation of parish and municipal ordinances. La. R.S. § 13:2563.3. The legislature grants Judge Lambert the authority to issue a bail schedule that fixes the amount of bail to be set in misdemeanor cases. La. Code Crim. Proc. art. 341. 6. Defendant Jeffrey F. Wiley is the Sheriff of Ascension Parish. Defendant Wiley is designated as “keeper of the public jail . . . and shall preserve the peace and apprehend public offenders,” La. R.S. § 13:5539(C). He has implemented a policy of following the bail schedule set by Judge Lambert and detains all arrestees who are unable to pay secured money bail after arrest.
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Factual Background A. The Named Plaintiff’s Arrest. 7. Rebecca M. Snow is a 33-year-old mother of two children. See Exhibit 1, Declaration of Rebecca Marie Snow. 8. Ms. Snow was arrested by Gonzales Police Department officers on August 24, 2015. She was charged with two misdemeanor offenses: Theft under $500 and Entry on or Remaining in Places or on Land after Being Forbidden. 9. Pursuant to Ascension Parish Sheriff’s Office policy, Ms. Snow was taken to jail and told that she would be released if she paid A.P.S.O. $289.50 bail for each charge, totaling $579. 10. Ms. Snow is indigent. She has no significant assets or regular income. She has no bank account and owns no real property. She cares for her two children. She receives about $500 per month in Supplemental Nutrition Assistance Program benefits and is eligible for Medicaid coverage. 11. Ms. Snow saw a judicial officer via video hearing for appointment of counsel on the morning after her arrest. Ms. Snow asked the judicial officer to review her bail. The judicial officer refused to hear Ms. Snow’s argument and indicated that it was not her function to review bail. An A.P.S.O. deputy told Ms. Snow that she was asking the wrong judge about her bail. Ms. Snow asked an A.P.S.O. deputy when her next appearance before a judge would be. A.P.S.O. deputies could not tell Ms. Snow when her next hearing would be, saying that they wouldn’t know until the court sends A.P.S.O. a docket sheet on the morning of her hearing.
4

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B. The Defendants’ Policies and Practices. 12. The named Plaintiff would be released immediately by Defendant Wiley if she or someone acting on her behalf paid the amount of money set by the bail schedule. 13. The treatment of the named Plaintiff and other Class members is caused by and is representative of the Defendants’ post-arrest detention policies and practices. 14. As a matter of policy and practice, when law enforcement officers in Ascension Parish make an arrest for a traffic or misdemeanor violation, Ascension Parish Sheriff’s Office employees inform the arrestee at booking that the person will be released immediately if the person pays money set by a fixed schedule.2 The arrestee is told that the arrestee will remain in jail if the arrestee is not able to make that payment. 15. Initial appearances before a judicial officer for the purpose of appointing counsel and considering pretrial release are not available on a daily basis. District Court judges for the Twenty-third Judicial District Court conduct “jail call” video hearings for appointment of counsel for arrestees facing municipal or State misdemeanor charges under the jurisdiction of Ascension Parish Court. Jail calls may be held two or three times per week, but their frequency and timing varies with the schedule of the district court judge who is “on duty” for a particular week. An arrestee too poor to buy her way out of jail could wait up to five days before appearing before a judge in a “jail call.” Because even those hearings are occasionally cancelled, an impoverished arrestee might spend even longer in jail before a first court appearance. In Ms. Snow’s case, the judicial officer presiding over her “jail call” refused to consider Ms. Snow’s request for an individualized bail setting and indicated that it was not her function to review bail.
2 Arrestees are also told that they can contract with a private bonding company by paying the statutorily mandated 12% of the scheduled bail amount, La. R.S. § 22:1443, but many impoverished arrestees cannot afford even that amount. Moreover, private bonding companies are under no obligation to provide a bond and can refuse to pay any bond in their discretion.
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16. After an arrest, it is the policy of Defendants to apply the secured “bail schedule,” see Exhibit 2, which generally sets payment amounts between $112 and $1,169.50 depending on the offense of arrest. Defendants do not deviate from that schedule.
17. In the period between an arrest and the first appearance before a judge, Defendants do not allow post-arrest release on recognizance or with an unsecured bond (in which a person would be released by promising to pay the scheduled amount if the person later does not appear). Instead, Defendants require that the money payment amount be secured (i.e., paid up front before release).
18. Many of Ascension Parish’s arrestees within the jurisdiction of the Ascension Parish Court are released soon after arrest upon payment of the scheduled amount of money. Others remain detained for varying lengths of time until they or their families are able to borrow sufficient amounts of money or arrange for third-party payment. Many others, like the named Plaintiff, who are too poor even to find anyone to pay the money bond for them, are kept in jail at least until they appear before a judge who will hear a motion on bail reduction.
Class Action Allegations 19. The named Plaintiff brings this action, on behalf of herself and all others similarly situated, for the purpose of asserting the claims alleged in this Complaint on a common basis. 20. A class action is a superior means, and the only practicable means, by which the named Plaintiff and unknown Class members can challenge the Defendants’ unlawful povertybased post-arrest detention scheme. 21. This action is brought and may properly be maintained as a class action pursuant to Rule 23(a)(1)–(4) and Rule 23(b)(2) of the Federal Rules of Civil Procedure. 22. This action satisfies the numerosity, commonality, typicality, and adequacy
6

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requirements of those provisions. 23. The Plaintiff proposes one Class seeking declaratory and injunctive relief. The
Declaratory and Injunctive Class is defined as: all arrestees unable to pay for their release pursuant to Defendants’ secured bail schedule who are or who will be in the custody of Defendant Sheriff Wiley.
A. Numerosity. Fed. R. Civ. P. 23(a)(1). 24. Each arrestee is presented with the Defendants’ standard money-bond choice of pay or jail. Arrestees are held in jail for varying lengths of time depending on how long it takes them to make the payment that the Defendants require for their release. 25. Some arrestees are able to pay for release immediately. Others are forced to wait a day or more until they or family members can make the payment. Others are not able to pay or to find someone else to pay for them even after several days of detention. 26. The number of current and future arrestees subjected to this policy if it is not enjoined is innumerable. Ascension Parish Sheriff’s Office jail records show that there are often several Ascension Parish Court arrestees every day who have not been able to pay for their release. Including future arrestees, the proposed Class contains thousands of people. B. Commonality. Fed. R. Civ. P. 23(a)(2). 27. The relief sought is common to all members of the Class, and common questions of law and fact exist as to all members of the Class. The named Plaintiff seeks relief concerning whether the Defendants’ policies, practices, and procedures violate the rights of the Class members and relief mandating the Defendants to change their policies, practices, and procedures so that the constitutional rights of the Class members will be protected in the future. 28. These common legal and factual questions arise from one central scheme and set
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of policies and practices: the Defendants’ post-arrest detention schedule. The Defendants operate this scheme openly and in materially the same manner every day. The material components of the scheme do not vary from Class member to Class member, and the resolution of these legal and factual issues will determine whether all of the members of the class are entitled to the constitutional relief that they seek.
Among the most important, but not the only, common questions of fact are: • Whether Defendants have a policy and practice of using a “bail schedule” to determine the amount of money necessary to secure post-arrest release; • Whether Defendants require that scheduled amount of money to be paid up front before it will release a person from jail; • What standard post-arrest procedures Defendants performs on misdemeanor arrestees; for example, whether Defendants have any other alternate procedures for promptly releasing indigent people unable to afford a monetary payment.
29. Among the most important common question of law are: • Whether a secured “bail schedule” setting standard amounts of money required up front to avoid post-arrest detention violates the Fourteenth Amendment’s due process and equal protection clauses.
C. Typicality. Fed. R. Civ. P. 23(a)(3). 30. The named Plaintiff’s claims are typical of the claims of the other members of the Class, and she has the same interests in this case as all other members of the Class that she represents. Each of them suffers injuries from the failure of the Defendants to comply with the basic constitutional provisions: they are each confined in jail because they could not afford to pay the Defendants’ standardized cash bond amount. The answer to whether the Defendants’ scheme of policies and practices is unconstitutional will determine the claims of the named Plaintiff and every other Class member. 31. If the named Plaintiff succeeds in the claim that the Defendants’ policies and practices concerning post-arrest detention violate her constitutional rights, that ruling will likewise
8

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benefit every other member of the Class.
D. Adequacy. Fed. R. Civ. P. 23(a)(4).
32. The named Plaintiff is an adequate representative of the Class because her interests
in the vindication of the legal claims that she raises are entirely aligned with the interests of the
other Class members, who each have the same basic constitutional claims. She is a member of the
Class, and her interests coincide with, and are not antagonistic to, those of the other Class members.
33. There are no known conflicts of interest among members of the proposed Class, all
of whom have a similar interest in vindicating their constitutional rights in the face of their
unlawful treatment by their local government.
34. Plaintiffs are represented by attorney William P. Quigley3 and attorneys from Equal
Justice Under Law4 and the Roderick and Solange MacArthur Justice Center in New Orleans
(“MacArthur Justice Center”),5 who have experience in litigating complex civil rights matters in
federal court and knowledge of both the details of the Defendants’ scheme and the relevant
constitutional and statutory law.
3 William Quigley has practiced law in Louisiana for nearly forty years, during which time he has litigated numerous class action civil rights cases in federal court. He holds the positions of Professor of Law and Director of the Stuart H. Smith La Clinic and Center for Social Justice and the Gillis Long Poverty Law Center at Loyola University New Orleans College of Law. 4 Equal Justice Under Law is a non-profit civil rights organization based in Washington, D.C. The organization is funded in part by the Harvard Law School Public Service Venture Fund. Counsel from Equal Justice Under Law was recently lead counsel in a landmark federal civil rights class action lawsuit against the City of Montgomery for engaging in similar practices. In that case, the United States District Court for the Middle District of Alabama issued a preliminary injunction condemning and forbidding the City’s similar jailing of impoverished people with unpaid debts, and the case was successfully settled after the City agreed to compensate the Plaintiffs and to the entry of an injunction reforming its entire municipal debt-collection regime. See Mitchell et al. v. City of Montgomery, 14-cv186 (M.D. Ala. 2014). Counsel is also lead counsel in recent similar challenges to the fixed “bail schedule” schemes employed by the City of Clanton, Alabama, and the City of Velda City, Missouri. See Varden et al. v. City of Clanton, 15-cv-34 (M.D. Ala 2015); Pierce et. al. v. City of Velda City, 15-cv-570 (E.D. Mo. 2015). In each case, the City of Clanton and the City of Velda City agreed to end their use of a fixed cash bail system for new arrestees. 5 The MacArthur Justice Center is a non-profit public interest law firm. Undersigned counsel Katie Schwartzmann, the co-Director of the MacArthur Justice Center, has practiced law in Louisiana for ten years and has litigated a wide variety of complex civil matters in state and federal court. She is presently class counsel for thousands of prisoners in the Orleans Parish Prison. Undersigned counsel Eric Foley, staff attorney at the MacArthur Justice Center, worked for two years as a federal judicial clerk in the District Court of Puerto Rico before beginning his practice of law in Louisiana in 2011. He has litigated civil rights cases at the trial and appellate stages in state court.
9

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35. The efforts of Class counsel have so far included investigation of Defendants’ money-based pretrial detention system, interviews of jail inmates and attorneys practicing in the area, consultation with local and national experts, and research regarding the legality of Defendants’ secured money-bail regime.
36. Class counsel have studied the way that post-arrest detention systems function in other cities and counties in order to investigate the wide array of lawful options in practice for municipal entities.
37. Class counsel also have experience litigating similar challenges in other jurisdictions and years of experience litigating complex and important cases in Louisiana federal courts.
38. As a result, counsel have undertaken significant efforts toward becoming intimately familiar with the Defendants’ scheme and with all of the relevant state and federal laws and procedures than can and should govern it. The interests of the members of the Class will be fairly and adequately protected by the named Plaintiff and her attorneys.
E. Rule 23(b)(2). 39. Class action status is appropriate because the Defendants, through the policies, practices, and procedures that make up their post-arrest detention scheme, have acted in the same unconstitutional manner with respect to all class members. Defendants have created and applied a simple scheme of post-arrest detention and release: it charges monetary sums typically ranging between $112 and $1,169.50 for every arrest. Defendants release those who can pay and detain those who cannot. Impoverished arrestees who remain detained eventually have their first appearance before a judge in the form of a video hearing that is held two or three times per week with a duty judge of the Twenty-third Judicial District Court.
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40. The Class therefore seeks declaratory and injunctive relief to enjoin the Defendants from continuing in the future to detain impoverished arrestees who cannot afford money payments. Because the putative Class challenges the Defendants’ scheme as unconstitutional through declaratory and injunctive relief that would apply the same relief to every member of the Class, Rule 23(b)(2) certification is appropriate and necessary.
41. Injunctive relief compelling the Defendant Sheriff Wiley to comply with these constitutional rights will similarly protect each member of the Class from being subjected to the Defendants’ unlawful policies and practices. A declaration and injunction stating that the Ascension Parish Court cannot use a secured money “bail schedule” that jails indigent arrestees but frees arrestees with financial means would provide relief to every member of the Class. Therefore, declaratory and injunctive relief with respect to the Class as a whole is appropriate.
42. Plaintiff seeks the following relief and hereby demands a jury in this cause for all matters so appropriate.
Claims for Relief Count One: Defendants Violate Plaintiff’s Rights By Jailing Her Solely Because She Cannot Afford a Money Payment. 43. Plaintiff incorporates by reference the allegations in paragraphs 1–42. 44. The Fourteenth Amendment’s due process and equal protection clauses have long prohibited keeping a person in jail because of the person’s inability to make a monetary payment. Defendants violate Plaintiff’s rights by placing and keeping her in jail when she cannot afford to pay the amount of money set by the generic secured bail “schedule” used by Defendants.
Request for Relief WHEREFORE, Plaintiff and the other Class members request that this Court issue the following relief:
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a. A declaratory judgment that the Defendants violate the named Plaintiff’s and Class members’ constitutional rights by promulgating and enforcing policies that result in jailing Plaintiff and Class and keeping them in jail solely because they are poor and cannot afford to pay an amount of money to secure release;
b. An order and judgment temporarily, preliminarily and permanently enjoining Defendant Sheriff Wiley from enforcing the unconstitutional post-arrest money-based detention policies and practices against the named Plaintiff and the Class of similarly situated people that she represents;
c. An order and judgment granting reasonable attorneys’ fees and costs pursuant to 42 U.S.C. § 1988, and any other relief this Court deems just and proper.
Respectfully submitted,
/s Katie M. Schwartzmann Katie M. Schwartzmann, La. Bar No. 30295 Lead Trial Counsel Roderick & Solange MacArthur Justice Center 4400 S. Carrollton Ave. New Orleans, LA 70119  (504) 620-2259 (p) (504) 208-3133 (f) katie.schwartzmann@macarthurjustice.org Eric A. Foley, La. Bar No. 34199 Roderick & Solange MacArthur Justice Center 4400 S. Carrollton Ave. New Orleans, LA 70119  (504) 620-2259 (p) (504) 208-3133 (f) eric.foley@macarthurjustice.org
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William P. Quigley, La. Bar No. 07769 7214 Saint Charles Ave Campus Box 902 New Orleans, LA 70118-3538 Phone: (504) 861-5590 Fax: (504) 861-5440 quigley77@gmail.com
Alec Karakatsanis, D.C. Bar No. 999294 (Pro Hac Vice Application Pending) Co-Founder Equal Justice Under Law 916 G Street, NW Suite 701 Washington, DC 20001 (202)-681-2409 alec@equaljusticeunderlaw.org Attorneys for Plaintiffs
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Case 3:15-cv-00567-SDD-RLB Document 1-2 08/25/15 Page 1 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
____M__id_d_l_e_DDisitsrtircitctoof fL_o_u_is_i_a_n_a___

REBECCA M. SNOW, et al.,
Plaintiff(s)
v. MARILYN M. LAMBERT, in Her Official Capacity as Judge of Ascension Parish Court, and JEFFREY F.
WILEY, in His Official Capacity as Sheriff of Ascension Parish Defendant(s)

)

)

)

)

)

) )

Civil Action No. 15-cv-00567

)

)

)

)

)

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Judge Marilyn M. Lambert 828 South Irma Blvd., Building 2 Gonzales, LA 70737

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are: Katie M. Schwartzmann
MacArthur Justice Center 4400 S. Carrollton Ave. New Orleans, LA 70119

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Date:

CLERK OF COURT
Signature of Clerk or Deputy Clerk

Case 3:15-cv-00567-SDD-RLB Document 1-2 08/25/15 Page 2 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 15-cv-00567

PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any) Judge Marilyn Lambert

was received by me on (date)

.

u I personally served the summons on the individual at (place)

on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date)

, and mailed a copy to the individual’s last known address; or

u I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization)
on (date)

, who is ; or

u I returned the summons unexecuted because

; or

u Other (specify): .

My fees are $

for travel and $

for services, for a total of $

0.00

.

I declare under penalty of perjury that this information is true.

Date:

Server’s signature Printed name and title

Additional information regarding attempted service, etc:

Server’s address

Case 3:15-cv-00567-SDD-RLB Document 1-3 08/25/15 Page 1 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
____M__id_d_l_e_DDisitsrtircitctoof fL_o_u_is_i_a_n_a___

REBECCA M. SNOW, et al.,
Plaintiff(s)
v. MARILYN M. LAMBERT, in Her Official Capacity as Judge of Ascension Parish Court, and JEFFREY F.
WILEY, in His Official Capacity as Sheriff of Ascension Parish Defendant(s)

)

)

)

)

)

) )

Civil Action No. 15-cv-00567

)

)

)

)

)

SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Sheriff Jeffrey F. Wiley 828 S. Irma Blvd. Gonzales, LA 70737

A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are: Katie M. Schwartzmann
MacArthur Justice Center 4400 S. Carrollton Ave. New Orleans, LA 70119

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.

Date:

CLERK OF COURT
Signature of Clerk or Deputy Clerk

Case 3:15-cv-00567-SDD-RLB Document 1-3 08/25/15 Page 2 of 2

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 15-cv-00567

PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any) Sheriff Jeffrey F. Wiley

was received by me on (date)

.

u I personally served the summons on the individual at (place)

on (date)

; or

u I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date)

, and mailed a copy to the individual’s last known address; or

u I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization)
on (date)

, who is ; or

u I returned the summons unexecuted because

; or

u Other (specify): .

My fees are $

for travel and $

for services, for a total of $

0.00

.

I declare under penalty of perjury that this information is true.

Date:

Server’s signature Printed name and title

Additional information regarding attempted service, etc:

Server’s address

Case 3:15-cv-00567-SDD-RLB Document 1-4 08/25/15 Page 1 of 2

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Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 1 of 6

Jun. 3. 2015 3:12PM

JUDGE LAMBERT
APSO
BOND SCHEDULE

NO. 1355 P.

09/0-t/ U

EXHIBIT

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CHARGE CODE
14:93.1 26:90(3)A
32:308 14:37 14:37.4 32:417 14:27.67 32:101C 26 :2 7 4 14:34.2
14:34.3
32:329A 32:318 47:536-2 32:58
14:80.1 32:289.1 14:93.2.1 32:284 ART:4-l
14:73.7
32:309
14:95.4
14:26 14:91.5 14:92 32:262 14:56 14:56.1 14:59 14:74 14:63 32:82A 14:102
4-lA 32:413

DESCRIPTION
Abuse of Toxic Vapors Acts Prohibited on Licensed Premises Additional Lights Required for Aggravated Assault Aggravated Assault with Gun
Allowing Unlicensed Driver to Drive
Attempted Theft Avoiding an Intersection Bannaid License - Oper. Without permit Battery on a Police Officer (15 day mandatory jail) Battery on a School Teacher (15 day mandatory jail)
Bicycle rear lamp and side reflectors
Blue Lights for Police Use Cancelled License Plate Careless Operation Careless Operation (with accident) Carnal Knowledge of Juvenile Cellular Use "While Driving (Court Mandatory if accident) Child Desertion Children Riding in Rear Bed of Truck Closing Law Computer Tampering Color of Clearance Lights Consent to Search
to Simple Battery Consumption of Alcohol Under 21 Contributing to the Delinquency of Juvenile Controlled Access Highways Criminal Damage to Property Criminal Damage Coin Operated Criminal Mischief Criminal Neglect ofFamily Criminal Trespassing Crossing Median on Divided Highway Cruelty to Animals (Death) Curfew - Where Alcoholic Beverage Damaged Driver's License

*Mandatorv Court Appearance

FINE COURT TOTAL *
COST

$100.00 $25.00

$194.50 $194.50

$294.50 *
$219.50

$5.00

$152.50

$157.50

$250.00 $500.00
$25.00

$194.50 $194.50 $152.50

$444.50 * $694.50 *
$177.50

$50.00 $10.00

$194.50 $152-50

$244.50 *
$162.50

$100.00

$194.50

$294.50

Set by Duty Ji;i:O.ge

$194.50

*

$500.00

$194.50

$694.50 *

$5.00 $100.00
$50.00 $50.00 $70.00 $500.00 $100.00 $100.00 $25.00 $250.00 $ 5 0 0 .00
$5 .00 $100.00 $100.00
$25.00 $100.00
$25.00
$100.00 $100.00
$25.00 $150.00 $100.00
$25.00 $100.00 $250.00
$25.00 $50.00

$152.50 $152.50 $152.50 $152.50 $152-50 $194.50 $152.50 $194.50 $152.50 $194.50 $194.50 $152.50 $194.50 $194-50 $194.50
$194.50
$152.50
$194.50 $194.50
$194.50 $194.50
$194.50 $152.50
$194.50 $194.50
$194.50
$152.50

$157.50
. $252.50 *
$202.50
$202.50
$222.50
$694.50 *
$252.50
$294.50 *
$177.50 *
$444.50
$694.50 *
$157.50
$294.50
$294.50 * $219.50 * $294.50 *
$177.50
$294.50 * $294.50 * $219.50 * $344_50 * $294-50 *
$177.50
$294.50 * $444.50 *
$219.50
$202.50

Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 2 of 6

=Jun. 3. __2 015=

32:237

D,isobeying Barricades

32:123

Disobey Stop or Yield Signs

32:56

Disobeying a Police Officer

32:171 . Disobeying Train Signals

32 : 171

Disobeying Train Signals - With Accident

14:103

Disturbing the Peace

14:35.3

Domestic Abuse Battery •Bond set by Di$t. Court Judge

14:103. l DTP by Loud Music

32 :65

Drag Racing

32 :4 0 6

Driver's License - Failure to Change

32:326

Driving Lamps Required

32:71

Driving Left of Center

32:290

Driving Through Ditch

32:101

Driving Through Private Property

32:415

Driving Under Suspension

14:98.3

DUS because of DWI (\5 dn% lllinirnum-N¢ tir'l<a- l'&n. fail time)

32:326C 32:301 32:411 32:73 14:98 14:98.C 14:63.3 32:412 47:508 32:1304E 32:406 32:301A 32:231 47:501 32:871 14:220 32:121 32:125 32:124 32:1308 14:1333 14:133 32:234A 14:108.1 32 :286 32:81 32:1308 40:1321 32:414.1 14 :68 .7 32:300.3

Driving with Parking Lights Only

Driving Without Headlights

Driving w/o a Valid Driver's License

Driving Wrong Way on On-Way Street
DWI - 1st Offense

DWI-2na Offense

Entry on or Remaining on Places

Expired

License/No DL in Possession

Expired License Plate Op

Expired MVI Sticker

Failure to Change Address

Fail to Dim Headlights W/O Accident

Failure to Obey Signs/Signals

Failure to Register Vehicle

Failure to Report Accident

Failure to Return Leased Movable

Failure to Yield

Failure to Yield to Emergency

Failure to Yield When Entering

FakeMVI

Falsifying Drug Screen

Filing False Public Records

Flashing Red & Yellow Signals (Disobeying)
Flight From an Officer

Following Emergency Vehicle

Fallowing too Close

Forged MVI Sticker

Fraudulent LD. Card

-Fraudulent Use ofDriver?s License

Fraudulent Use of Sales Receipts

Funeral Procession

$25 .00 $25.00 $25.00 $100.00 $100.00
$100.00
$50.00 $300.00 $150.00 $100.00
$5.00 $5.00 $10.00 $25.00 $25.00 $150.00 $500.00 bond $5.00 $25 .00 $50.00 $25.00 $500.00 $800.00 $100.00 $5.00
$10.00
$5 .00 $5.00 $5 .00 $25.00 $100.00 $25.00 $100.00 $25.00 $25.00 $25.00 $100.00 $100.00 $100 .00 $25.00 $100.00 $25 .00 $25.00
$100.00
$100-00 $100.00 $100.00 $100.00

$N o. LJL

1355=P.
.JV

.

j

)l377

•

50

$152.50

$177.50

$152.50

$177.50

$194.50 $152.50

$294.50 *
$252-50

$152.50 $194.50 $194.50 $194.50
$152.50

$252.50 * $244.50 * $494.50 * $344.50 *
$252.50 =I=

$155.50

$157.50

$152.50

$157.50

$152.50

$162.50

$152.50

$177.50

$152.50

$177.50

$152.50

$302.50 *

$152.50 $152.50 $152.50 $152.50
$344.50
$369.50 $194.50 $152.50 $152.00 $152.50 $ 1 5 2 .50 $152.50 $152.50 $152.50
$152.50
$194.50 $152.50 $152.50 $152.50 $152.00 $194.50 $194.50 $152.50 $194.50 $152.50 $152.50 $152.50 $194.50 $152.50
$194.50
$152.50

$157.50 $177.50 $202.50 $177.50
$844.50 *
$1,169.50 * $294.50 *
$157.50 $162.50 $157.50 $157.50 $157.50 $177.50 $252.50 $177.50
$294.50 *
$177.50 $177.50 $177.50
$252.50 *
$294.50 * $294.50 *
$177.50
$294.50 *
$177.50 $177.50
$252.50 *
$294.50 * $252.50 * $294.50 *
$252.50

Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 3 of 6

=Jun. 3. 2015= 3_:

32:415.1 14:100

Hardship License Hit & Run Driving

32:378.2 Ignition Interlock Device

DCO 3-29 14:95

Illegal Acts on Licensed Premises

(D

City Code)

Illegal Carrying of Weapon

14:69

Illegal Possession of Stolen Things

32:295.2 Illegal Use ofHeadphones

32 :361.1 Illegally Tinted Windows

32:64B

Impeding the Flow of Traffic

32:281

Improper Backing

47:507

Improper Display of License

32:79

Improper Lane Usage

32:122

Improper Left Turn

32 :3 1 7

Improper Lights

32:352

Improper Mufflers

32:74

Improper Passing

32:141

Improper Parking

14:92.2 32:101 14 :45 . l

Improper Supervision Improper Turning at Intersection Interfering: with Custody of Child

40:1390 Interfering with State Police

14:71

Issuing Worthless Checks

14 :104
32:295.3

Keeping a Disorderly Place Leaving Child unattended/unsupervised in Motor Vehicle (while running)

32:398

Leaving the Scene of an Accident

14:105

Letting a Disorderly Place

32:291

Liability for Damage to Highway

32:304C
30:2531
5-20 14:107 32 :2 9 7 14:133.2 14:333
47:5050 14:39 14:39.1 32:295 4-41 32:52
32:411D 3 2 :301
32:861
32:403.4 3 2 :5 2 M C

License

Light Required

Littering

Livestock at Large

Loitering (Vagrancy)

Low Rider Vehicle Clearance Less

Misrepresentation During Booking

Misrepresentation of Age to Obtain Alcoholic

Beverages

Misuse of Dealer Plate

Negligent Injuring

Negligent Vehicular Injuring

No Child Restraint

No Dancer's License

No Driver:s License Issued

No Driver's License in Possession

No Headlights

No Liability Insurance

No Medical Cert. in Possession (18-wheeler)

No Motorcycle Endorsement

$100.00 $100.00 $125.00 $500.00 $100.00
$100.00 $100.00
$25.00 $150.00
$25.00 $25.00
$5.00 $25.00 $25.00
$5.00 $25.00 $25 .00
$5 .00 $100.00
$25.00 $150.00 $150.00 $100.00 $100.00
$25 .00
$25.00 $100 .00
$25.00
(plus rest.)
$5.00
$300.00
$25.00 $25.00 $25.00 $100.00 $25.00
$5.00 $125.00 $500.00 $100.00 $100 .00
$50.00 $5 .00 $5.00
$150.00
$5.00 $5.00

·No. 1355=p. 4

$ .l 7'1' •.JV

J>-'94.50 *

$152.50

$252.50 *

$194.50

$319.50 *

$152.50

$652.50 *

$194.50

$294.50

$194.50 $194.50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50 $107.00 $194.50 $152.50 $194.50 $194.50 $194.50 $194.50 $152.50
$152.50 $194.50 $152.50
$152.50 $194.50 $194.50 $194.50 $152.50
$194.50
$194.50
$194.50 $194.50 $194.50 $152.50 $194 .50 $152.50 $152.50 $152.50 $152.50 $152.50 $152.50

$294.50 * $294.50 *
$177.50 $302.50 $177.50 $177.50 $157.50 $177.50 $177.50 $157.50 $177.50 $177.50 $112.00
$294.50 *
$177.50
$344.50 * $344.50 * $294.50 * $294.50 * $177.50 *
$177.50
$294.50 *
$177.50
$157.50
$494.50 *
$219.50
$219.50 *
$177.50
$294.50 * $219.50 *
$199.50 $319.50 Jjl
$694.50 *
$252.50 *
$294.50 $202.50
$157.50
$157.50
$302.50
$157.50 *
$157.50

Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 4 of 6

3. 2015= 3: 13PMtorC)JUDGE

32:53D No MVI Sticker

. 32:863.l No Proof of Liability Insurance

47:506

No Registration Papers

32:295.1 No Seat Belt

32:304 No Tail Lights

32:104

No Turn Signal

32:56B No U-Turn

32:51

No Vehicle License Plate

APO 22-30 No Wake Zone

32:169

Obeying Train Signals

32:378

Obscene Sticker

14:100.0 Obstruction of Public Passage

32:300

Open Container

32:198

Operating Motorized Bike

32:143

Parking, General Pl."ovisions

40:1742.B 40:1742.B

Parking in Fire Zone

Parking

in

Handicapped

(l

51 )

Parking in Handicapped (2nd)

32:77

Passing in No Passing Zone

32:80

Passing a Stopped School Bus

32:74

Passing Vehicle on Right

32:212

Pedestrian May Not Walk in Front of Vehicle

40:1033 Possession ofDrug Paraphernalia

14:95.5 Possession of Firearm on premises of alcoholic

beverage outlet

40:966C Possession of Schedule I CDS (Marijuana)

14:91.13 Possession ofMarijuana in presence of minor

14:93.12 Possession/Purchase of Alcohol Under 21

14:91.8(F) Possession/Sale of Tobacco Product under 18

14:103(3) Public Drunk

14:93.13 Purchase of Alcohol on behalf of Person Under

21

32:171

Railroad Crossing

14:99

Reckless Operation

14:98.2 Refusal of Chemical Test

14:108

Resisting an Officer

32 :53A Riding

on highway

38:213

Riding Motor Vehicle on Levee

32:284B Riding on Running Boards

14-3.A

Roadside Solicitation

Sec_

Roaming Dog

5-58

Running at Large

32:232.3 Running Red Light (No Accident)

$25.00
$25.00
$5.00 $25.00 $25.00
$25.00
$25.00 $25.00 $50.00 $25.00 $100.00 $25.00 $25.00 $100.00 $25.00 $5.00 $100_00 $300.00 $500.00 $25.00 $175.00
$25.00
$25.00 $100.00 $250.00
$500.00 $100.00
$25.00
$25.00
$50.00 $100.00
$100.00
$100.00
$300.00 $100.00
$50.00 $25.00 $25.00 $25.00 $25.00 $25.00 $25.00

$152 .50 $152.50 $152.50
None $152.50 $152.50 $152.50 $152.50 $194.50 $152.50 $152.50 $194_50 $152.50 $152.50 $107.00 $152.50 $194.50 $194.50 $152.50 $152.50 $152.50 $152.50 $244.50 $194.50
$244.50 $194.50 $194.50 $194.50 $194.50 $194.50
$152.50 $199.50 $194.50 $194.50 $152.50 $152.50 $152.50 $194.50 $194.50 $194.50 $152.50

. .i>l77-50
$177.50 $157.50 $177-50 $25.00 $177.50 $177_50 $177.50 $202.50 $219 .50 $252.50 $177.50 $219.50 $252-50 $177.50 $112-00 $252.50 $494-50
$694-50 *
$177.50
$327.50 *
$177.50 $177.50 $344.50
$444.50 *
$744.50 *
$294.50 >Ir
$219.50 *
$219.50 * $244.50 *
$294.50 *
$252.50
$299-50 * $494_50 *
.$294.50 *
$202.50 *
$177.50 $177.50 $219.50
$219.50 * $219.50 *
$177.50

14:93.11 14:81.11
14:38 14 :35

Sale of Alcohol to Minor Sexting Simple Assault Simple Battery

$500.00 $250.00
$50.00 $100.00

$194.50 $194.50 $194-50 $194.50

$694.50 * $444.50 *
$244 .50
$294.50 *

Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 5 of 6

=Jun. 3.- - 2015=- ·3--:-1-3--P--M11(>= -JUDGE AAA. _.ucle

32;378.3

Sound System on Outside of Vehicle

($25 o{ (Irie must be; forwarded to State

32:378.3(r;))

47:536-8 Switched License Plate

14:285 Telephone Harassment

32:300-5 Texting While Driving

14:67

Theft

14:70.6 Theft of Alarm, Deactivation Device

14:67.17 Theft ofMotor Vehicle Fuel

14:67.6 Theft ofUtilities

14: 122.2 Threatening a Police Officer

32:102

Turning on Curve or Crest of Grade Prohibited

32:145

Unattended Motor Vehicle

14:67-3

Unauthorized Use of Access Card

14:68

Unauthorized Use of Movable

14:102.14 Unlawful Ovvnership of Dangerous Dog

14:12.15 Unlawful Ownership of Vicious Dog

14:91.1

Unlawful Presence of Sexual Violent Predator

14:93.11 Unla'Wful Sale of Alcohol to Minors

32:52

Unlicensed Driver

32:1301 Unsafe Vehicle

32:383

Unsecured Load

14:107

Urinating in Public (Vagrancy)

14:79

Violation ofProtective Order

15-9 (D'Ville Otd) Walking on Roadway

32:303D White Headlamp required

$150.00
$500-00
$50.00 $100.00 $100.00
$1 oo_oo
$100.00
$100-00 $100-00
$100.00
$25_QQ $25 _00 $100_00 $100-00
$100.00
$100.00
$500.00
$50.00 $25.00 $25_QQ $100.00
$500-00 $25_00
$25.00

$

5= P ·.v}J2.50

$152.50

$652.50

$152.50 $194.50
$152.50 $194.50 $194.50 $194.50 $194.50 $194.50 $152.50 $152.50 $194.50 $194.50 $ 1 9 4 _50 $194.50 $194.50 $194.50 $152-50 $152.50 $152.50 $194.50 $194.50 $194.50
$152.50

$ 2 0 2 _5 0
$294.50 *
$252_50
$294.50 * $294.50 * $294.50 * $294.50 * $294.50 *
$ 1 7 7 .50 $177_50
$294_50 * $294-50 * $294.50 * $294.50 *
* $694.50 *
$202.50 $ 1 7 7 .5 0 $177.50
$294.50 *
$694_50 *
$219.50
$177.50

Court Costs:
Speeding: $157.50 Other Traffic: $152.50 Criminal Charges: $194.50 All BW Fees: $100.00

Case 3:15-cv-00567-SDD-RLB Document 1-5 08/25/15 Page 6 of 6

Jun. 3. 2015 3: 13PM JUDGE LAMBERT

No. 1355

APSO

TRAFFIC FINES FOR CARS, VANS AND SMALL TRUCKS

P. 7

25 MPH ZONE
35/25 .. . 172.50 36/25 ... 173.50 37/25 ... 174.50 38/25... 175. 50 39/25... 176.50 40/25 ... 177.50 41/25. -.178-50 42/25 .. . 179.50 43/25. -. 180.50 44/25 ... 181 .50 45/25 ... 182.50 46/25 ... 183.50 47/25 ... 184.50 48/25 ... 185.50 49/25 --.186.50 50/25 . -.187.50 51/25 ... 188.50 52/25 ... 189.50 53/25 ... 190.50 54/25 ... 190.50 55/25 ... 192.50 56/25 ... 193 .50 57/25 .. . 194.50 58/25 ... 195.50 59125. -.196.50 60125 .. .197.50

30MPHZONE
40/30. -.172.50 41/3 0... 173.50 42/30_ -. 174.50 43/30 ...175.50 44/30. -.176.50 45/30... 177.50 46/3 0. -. 178.50 47/30... 179.50 48/30... 180.50 49/30... 181.50 50/30__ .182.50 51/30... 183.50 52/30. -.184.50 53/30... 185.50 54/30... 186.50 55/30... 187.50 56/30. . . 188.50 57130 .. .189.50 58/30_ -.190 .50 59/30.. .191.50 60/30... 192.50 61/30. -'193.50 62/30... 194.50 63/30. -.195.50 64/30 ... 196.50 65/30. -.197.50

35 MPH ZONE
45/35_ -.172.50 46/35 ... 173.50 47/35. -. 174.50 48/35 ... 175.50 49/35 ... 176.50 50/35 ... 177.50 51135 ... 178.50 52/35 ... 179.50 53/35 ...180.50 54/35 .. . 181.50 55/35 ... 182.50 56/35. -.183-50 57/35 ... 184.50 58/35 __ . 185.50 59135 ... 186.50 60/35 ... 187.50 61/35 ... 188.50 62/35 ... 189.50 63/35 ... 190.50 64/35 ... 191.50 65/35 ... 192.50 66/35 ... 193.50 . 67/35 ... 194.50 68/35 ... 195.50 69/35 ... 196.50 70/35 ... 197.50

40MPHZONB
50/40 ... 172.50 51/40 ... 173 .50 52/40.. .174.50 53/40... 175.50 54/40 ... 176.50 55/40... 177.50 56/40 ... 178.50 57/40... 179.50 58/40... 180.50 59/40_ -.181.50 60/40... 182.50 61/40. -.183 .50 62/40... 184.50 63/40.. .185.50 64/40. -.186.50 65/40 . -.187.50 66/40... 188.50 67/40... 189.50 68/40.. .190.50 69/40.. . 191-50 70/40.. , 192.50 71/40... 193.50 72/40. -.194.50 73/40.. . 195.50 74/40... 196.50 75/40. -. 197.50

45MPHZONE
55/45_ -.172.50 56/45 ... 173.50 57/45 ... 174.50 58/45 ... 175.50 59145 .. .176.50 60/45 ... 177.50 61/45 ... 178.50 62/45. -.179.50 63145 ... 180.50 64/45 ... 181.50 65/45 ... 182.50 66/45 ... 183 .50 67/45 .. . 184.50 68/45 ... 185.50 69/45 ... 186.50 70/45 ... 187.50 71/45. -.188.50 72145 ... 189.50 73/45 . -.190.50 74/45 ... 191.50 75/45 ... 192.50 76/45 ... 193.50 77145 ... 194.50 78/45 ... 195 .50 79145 .. .196.50 80/45 ... 197.50

55 MPH ZONE 65 NIPH ZONE 70 MPH ZONE

65/55 ... 172.50

66/65 .. . 163.50

71170... 163 .50

66/55 ... 173.50

67/65 ... 164-50

72110 .. .164.50

67/55. -. 174.50

68/65 ... 165.50

73170 ... 165 .SO

68/55 ... 175.50

69/65 .. .166.50

74170... 166.50

69/55 ... 176.50

70/65 ... 167.50

75/70... 167.50

70/55... 177.50

71/65 ... 168.50

76170 ... 168.50

71/55 ... 178.50

72/65 ...169.50

77/70... 169.50

72/55. -.179.50

73/65 ... 170_50

78170 ... 170.50

73/55 ... 180.50

74/65. -.171-50

79170 ... 171.50

74/55... 181.50

75/65 ... 172.50

80/70. -. 172.50

75/55 ... 182.50

76/65 .. . 173.50

81-90/70 ... 257.50

76/55 ... 183.50

77/65 ... 174.50

91-99/70 ___307.50

77/55 ... 185.50

78/65 ... 175.50

100 MPH AND OVER

78/55 .. . 186.50

79/65 ... 176.50

COURT MANDATORY

79/55 ... 187.50

80/65... 177.50

80/55 ... 188.50

81-90/65 .. .257.50

81

... 257.50 91-99/65. -.307.50

91-99/55 ... 307.50 100 MPH AND OVER

100 :MPH AND OVER COURT MANDATORY

COURT MANDATORY

*Add $:25.00 if speeding in Construction Zo11e

 
 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

REBECCA M. SNOW, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED

CIVIL ACTION

VERSUS
MARILYN M. LAMBERT, IN HER OFFICIAL CAPACITY AS JUDGE OF ASCENSION PARISH COURT, AND JEFFREY F. WILEY, IN HIS OFFICIAL CAPACITY AS ASCENSION PARISH SHERIFF

NO. 15-567-SDD-RLB

RULING AND ORDER ON MOTION FOR TEMPORARY RESTRAINING ORDER

Plaintiff, Rebecca M. Snow (“Snow”), is an indigent person, charged with two misdemeanors violations1 in Ascension Parish. Plaintiff has been detained in the

Ascension Parish Jail since her arrest on misdemeanor charges on August 24, 2015.

Plaintiff has filed a Class Action lawsuit on behalf of herself and other similarly situated

persons alleging that her Due Process and Equal Protection rights guaranteed by the

Fourteenth Amendment have been violated by the Defendants’ post-arrest detention

policies and practices. Before the Court is Snow’s Motion for Temporary Restraining Order and Preliminary Injunction Against Defendant Wiley.2 For the following reasons,

the Court will grant in part and deny in part Snow’s Motion for Temporary Restraining

Order.

A temporary restraining order “is an extraordinary and drastic remedy, and should only be granted when the movant has clearly carried the burden of persuasion.”3

1 Rec. Doc. 1, Theft of property valued less than $500 and Entry or Remaining in Places or Land after Being Forbidden. 2 Rec. Doc. 4. 3 Anderson v. Jackson, 556 F.3d 351, 360 (5th Cir. 2009)(quotations omitted).
1

The purpose of a temporary restraining order is to “preserve the status quo and prevent irreparable harm just so long as is necessary to hold a hearing, and no longer.”4 A temporary restraining order may be issued without notice only if both of the following requirements are satisfied:
(A) specific facts in an affidavit or a verified complaint clearly show that immediate and irreparable injury, loss, or damage will result to the movant before the adverse party can be heard in opposition; and
(B) the movant’s attorney certifies in writing any efforts made to give notice and the reasons why it should not be required.5
The movant seeking injunctive relief “must satisfy a cumulative burden of proving each of the four elements enumerated before a temporary restraining order … can be granted.”6 These four elements are “(1) a substantial likelihood that the movant will prevail on the merits, (2) there is a substantial threat that irreparable harm will result if the injunction is not granted, (3) the threatened injury outweighs the threatened harm to the defendant, and (4) the granting of the preliminary injunction will not disserve the public interest.”7
After reviewing the record, the Court finds that Plaintiff has satisfied the procedural requirements of Rule 65(b) for the issuance of a temporary restraining order without notice. Specific facts in Ms. Snow’s verified Complaint evidence immediate and irreparable injury, namely continued detention without prior meaningful review or
4 RW Development, LLC v. Cuningham Group Architecture, Inc., 2012 WL 3258782, at *2 (S.D.Miss. Aug. 8, 2012)(citing Granny Goose Food, Inc. v. Bhd. of Teamsters & Auto Truck Drivers, 415 U.S. 423, 439 (1974); Canal Auth. of State of Florida v. Callaway, 489 F.2d 567, 573 (5th Cir. 1974)). 5 Fed.R.Civ.P. 65(b)(1)(A)-(B). 6 Clark v. Prichard, 812 F.2d 991, 993 (5th Cir. 1987). 7 Id.
2

assessment of appropriate bond conditions in violation of Louisiana Code of Criminal Procedure Articles 321, 334 and 325, which detention implicates individual liberty interests secured by the United States Constitution. Additionally, Ms. Snow’s attorneys have certified their efforts of providing notice to the Defendant Wiley, and have provided sufficient reasons as to why notice should not be required.
The Court further finds that Ms. Snow has satisfied each of the four elements necessary for a temporary restraining order. First, based upon the allegations in her verified Complaint, the evidence offered in support of her motion, and Louisiana’s Criminal Code of Procedure articles controlling bond,8 the Court finds that there is a substantial likelihood that Snow’s claims will succeed on the merits. Article 334 of the Louisiana Code of Criminal Procedure sets forth ten factors that a “court, commissioner, or magistrate” must consider when determining bail, including the financial ability of the defendant to give bail. Based on Snow’s verified Complaint, she is indigent and unable to pay the fixed bail established by the Ascension Parish “Bond Schedule”9 for misdemeanor offenses. According to the Plaintiff’s affidavit and the verified complaint, Snow was denied judicial review of her fixed bail. Additionally, in spite of the five bail options available to arrestees under article 312 of the Louisiana Code of Criminal Procedure, Snow was only afforded two options, either a cash payment of the scheduled bond amount or a secured bond. Snow is indigent, having no assets or real property with which to secure a surety bond. If a temporary restraining order is not entered, Ms. Snow will remain confined in Ascension Parish Prison pending her initial appearance or arraignment as a result of her inability to pay the fixed bond amount.
8 La. C.Cr.P. art. 312; La. C.Cr.P. art. 334; La. C.Cr.P. art. 325; La. C.Cr.P. art. 341. 9 Rec. Doc. 1-5
3

Ms. Snow has sufficiently demonstrated that this threat of injury is immediate and irreparable. Third, the alleged injury to Ms. Snow substantially outweighs any injury to Sheriff Wiley. Considering her extreme indigence, Snow poses little appreciable risk of non-appearance in misdemeanor court proceedings and the nature of the pending charges against her are not indicative of any risk to the community.
Finally the public interest will not be disserved by Ms. Snow’s immediate release from confinement. The Louisiana Supreme Court has long recognized Louisiana’s public policy regarding the requirement of bond:
“[B]ond must be reasonable. The public policy of the state favors bail, and under modern conditions criminals can be located and returned for trial or for service of sentence much more easily and efficaciously than in former years.” State v. Jones, 215 So. 2d 108, 112 (La. 1968) (quoting State v. Alvarez, 161 So. 17, 18 (La. 1935)). Louisiana law provides for five types of bail, including bail with an unsecured personal surety and bail without surety, with or without security.10 These options were not made available to Snow. Louisiana law also provides that “[a] person in custody may be released by an order of the court on his personal bail undertaking without the necessity of furnishing a surety.”11 Rule 65(c) instructs that a Court may issue a temporary restraining order only if the movant gives security in an amount that the court considers proper to pay the costs and damages sustained by any party found to have been wrongfully enjoined or restrained.12 “The Fifth Circuit has acknowledged that the amount of the security is
10 La. C.Cr.P. art. 312 (3), (4). 11 La. C.Cr.P. art. 325. 12 Fed.R.Civ.P. 65(c).
4

within the discretion of the district court, who can elect to impose no security at all.”13 This is an unusual case—it is grounded upon Ms. Snow’s indigent status. Therefore, in light of Ms. Snow’s indigency, the ability of Sheriff Wiley to secure Snow’s future appearance through alternative measures, and the Court’s determination that no costs or damages will be incurred by Sheriff Wiley during the pendency of the temporary restraining order, no security bond will be required.
Accordingly, is HEREBY ORDERED that: 1. The Motion for Temporary Restraining Order (Rec. Doc. 4) is hereby
GRANTED insofar as Sheriff Wiley is ORDERED to release Rebecca M. Snow immediately, either on her own recognizance or subject to an unsecured bond or other reasonable and lawful non-financial conditions. 2. The Motion for Temporary Restraining Order (Rec. Doc. 4) is hereby DENIED in all other respects. 3. A hearing to determine whether to convert this temporary restraining order into a preliminary injunction is set for an evidentiary hearing on Tuesday, September 1, 2015 at 9:30am in Courtroom 3.
Baton Rouge, Louisiana, August 27, 2015.
S _______________________________
SHELLY D. DICK, DISTRICT JUDGE MIDDLE DISTRICT OF LOUISIANA
13 New Orleans Home for Incurables, Inc. v. Greenstein, 911 F.Supp.2d 386, 412-13 (E.D.La. 2012)(citing City of Atlanta v. Metropolitan Atlanta Rapid Transit Auth., 636 F.2d 1084, 1094 (5th Cir. Unit B Feb. 13, 1981)(citing Corrigan Dispatch Co. v. Casa Guzman, 569 F.2d 300, 303 (5th Cir. 1978)).
5

 
 Case 3:15-cv-00567-SDD-RLB Document 29 09/03/15 Page 1 of 1

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

REBECCA M. SNOW, et al.
v.
MARILYN M. LAMBERT , in her official capacity as Judge of Ascension Parish Court, and JEFFREY F. W ILEY, in his official capacity as Ascension Parish Sheriff

Case No. 15-cv-00567-SDD-RLB (Class Action )

ORDER

CONSIDERING the Joint Motion for Settlement Agreement and Joint Stipulation of Dismissal1 filed by the Parties in the above captioned matter;

IT IS HEREBY ORDERED that the Motion is GRANTED and the Parties to the

Settlement Agreemenf attached to this Order are to comply with the terms of the

agreement.

IT IS FURTHER ORDERED that the Plaintiff's claims are dismissed with

prejudice subject only to the further jurisdiction of this Court to enforce the terms of the

settlement agreement.

_8_ Baton Rouge, Louisiana the

day of September, 2015.

1 Rec. Doc. 27. 2 Rec. Doc. 27-3.

SHELLY D. ICK, DISTRICT JUDGE MIDDLE DISTRICT OF LOUISIANA

Case 3:15-cv-00567-SDD-RLB Document 29-1 09/03/15 Page 1 of 5 Case 3:15-cv-00567-SDD-R LB Document 27-3 09/02/15 Page 1 of 5
UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

REBECCA M. SNOW. et al.
Plaintiffs,
v.
MAR ILYN M. LAMBERT, in her official capacity as Judge of Ascension Parish Court, and JEFFREY F. WILEY, in his officia l capacity as Ascension Parish Sheriff,
Defendants.

Case No. 15-cv-00567-SDD-RLB (Class Action)

SETTLEMENT AG REEMENT The Parties have worked together since the filing of this lawsuit to resolve the case. The parties agree to the following, and the parties jointly move the Court to enter a consent order requiring them to abide by their agreement.
I) The Plaintiff agrees to dismiss the lawsu it with prejudice subject to the Court retaining jurisdiction to enforce the Settlement Agreement and the terms of the Consent Judgment. Due to the speed with which Defendants have agreed to th is settlement, and the good faith agreement, Piainti ffs waive all attorneys' fees with the exception of filing costs.

Case 3:15-cv-00567-SDD-RLB Document 29-1 09/03/15 Page 2 of 5 Case 3:15-cv-00567-SDD-RLB Document 27-3 09/02/15 Page 2 of 5
2) The Defendants agree to the following:
a. No misdemeanor arrestee in the jurisdiction of the Ascension Parish Court wil l be held in jail after arrest pursuant to a secured monetary bond that
the arrestee cannot afford.

b. After arrest, all misdemeanor arrestees-except those expressly listed below- w ill be released on their own recognizance after the completio n of standard booking procedures. c. The Sheriff or Sheriff s designee w ill call the presiding judge after booking is complete for arrestees charged with offenses listed in (i}-{xi), and the presiding judge will make a case-by-case determination as to whether the arrestee will be released on recognizance. For those a rrested between the hours of 8 p.m. and 8 a.m., the Sheriff or Sheriffs designee may wait to call Judge Lambert until 8 a.m.

1.

Aggravated Assau lt, La. R.S. § 14:37;

11.

Battery on a Police Officer, Battery,§ 14:34.2;

111. Disturbing the Peace by Engaging in a fistic encounter,§

14: I03(A)( I), or by Engaging in any Act in a Vio lent and

Tumultuous Manner by Any Three or More Persons, §

14: I03(A)(4);

IV. Operating a Vehicle While Intoxicated, first offense,§§ 14:98(0)( I), 98. 1;

2

Case 3:15-cv-00567-SDD-RLB Document 29-1 09/03/15 Page 3 of 5 Case 3:15-cv-00567-SDD-RLB Document 27-3 09/02/15 Page 3 of 5
v. Operating a Vehicle While Intoxicated , second offense, §§ 14:98(0)(2), 98.2;
v1. Flight from an Officer,§ 14:108.1 VII. Resisting an Officer, § 14: I08 viii. Simple Assault. § 14:38 ix. Simple Battery,§ 14:35 x. Violation of Protect ive Orders, § 14:79 XL Theft of Goods under $500, second offense; § 14:67.10 d. In cases involv ing the misdemeanor offense of Domestic Abuse Battery, La. R.S. § 14:35.3, the court retains di scretion to operate the pretrial detention procedures set forth in La. Code of Criminal Procedure article 330.3.
e. Those arrested for the offenses listed in (i)- (xi) who were not released on recognizance after the Sheriff contacted the presiding judge shall be held in jai I without bond until a detention hearing held no later than the next business day. The detention hearing will meet the requirements of the due process and equal protection clauses ofthe Fourteenth Amendment, and no misdemeanor arres tee will be kept in jail on the basis ofa secured money bond that they cannot afford.
Respectfully submitted, 3

Case 3:15-cv-00567-SDD-RLB Document 29-1 09/03/15 Page 4 of 5 Case 3:15-cv-00567-SDD-RLB Document 27-3 09/02115 Page 4 of 5
s/ Katie M Schwartzmann Katie M. Schwmtzmann, La. Bar No. 30295 Roderick & Solange MacArthur Justice Center 4400 S. Carrollton Ave. New O rleans, LA 70 I 19 (504) 620-2259 (p) (504) 208-3133 (f) kat ie .s c h w a r t z m a n n @ macarthurju s tice.org
Eric A. Foley, La. Bar No. 34 199 Roderick & So lange MacArthur Justice Center 4400 S. Carro llton Ave. New Orleans, LA 70 I 19 (504) 620-2259 (p) (504) 208-3133 (f) eric.foley@ macarthurjustice.org
William P. Quigley, La. Bar No. 07769 7214 Sai nt Charles Ave Campus Box 902 New Orleans, LA 70 11 8-3538 Phone: (504) 861-5590 Fax: (504) 861-5440 qu igley77@gmail.com
Alec Karakatsanis, D.C. Bar No. 999294 (Pro Hac Vice Application Pending) Co-Founder Equal Justice Under Law 9 16 G Street, NW Su ite 70 I Washington, DC 20001 (202)-68 1-2409 a lec@equa ljusticeunderlaw.org
Attorneys for Plaint(ffs
sl David G. Sanders David G. Sanders, La. Bar No. 11 696 Assistant Attorney General Louisiana Department of Justice, Litigation Division P.O. Box 94005 Baton Rouge, LA 70804-9005 (225) 326-6300 sandersd@ag.state. la. us
Attorneyfor Defendant Judge Marilyn Lambert
4

Case 3:15-cv-00567-SDD-RLB Document 29-1 09/03/15 Page 5 of 5 Case 3:15-cv-00567-SDD-RLB Document 27-3 09/02/15 Page 5 of 5
Is Fred Schroeder Fred Schroeder, La. Bar No. I 1828 Usry Weeks & Matthews 16 15 Poydras Street, Suite 1250 New Orleans, LA 70 I 12 (504) 592-4600 fschroeder(@, uwmlaw.com
Attorneyfor Defendant Sheri.f!Jeffrey F. Wiley
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was fi led usi ng the Court 's CM/ECF fil ing system, wh ich will provide electronic notice to al l counsel of record.
s/ Katie M. Schwartzmann Katie M. Schwartzmann
5

 
 Case: 3:15-cv-567 As of: 09/20/2015 12:44 PM CDT 1 of 4
U.S. District Court Middle District of Louisiana (Baton Rouge) CIVIL DOCKET FOR CASE #: 3:15−cv−00567−SDD−RLB

CLOSED

Snow v. Lambert et al Assigned to: Judge Shelly D. Dick Referred to: Magistrate Judge Richard L. Bourgeois, Jr Cause: 42:1983 Civil Rights Act
Plaintiff

Date Filed: 08/25/2015 Date Terminated: 09/03/2015 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question

Rebecca M. Snow

represented by Katharine Murphy Schwartzmann Roderick &Solange MacArthur Justice Center 4400 S. Carrollton Avenue New Orleans, LA 70119 504−620−2259 Fax: 504−208−3133 Email: katie.schwartzmann@macarthurjustice.org LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alec Karakatsanis Equal Justice Under Law 916 G Street, NW Suite 701 Washington, DC 20001 202−681−2409 PRO HAC VICE

Eric Andrew Foley MacArthur Justice Center 4400 S. Carrollton Ave. New Orleans, LA 70119 (504) 684−2364 Email: eric.foley@macarthurjustice.org ATTORNEY TO BE NOTICED

William Patrick Quigley Loyola Law School 7214 St. Charles Ave. Box 902 New Orleans, LA 70118 504−861−5591 Fax: 504−861−5440 Email: duprestars@yahoo.com ATTORNEY TO BE NOTICED

V.
Defendant
Marilyn M. Lambert In Her Official Capacity as Judge of Ascension Parish Court

represented by David Glen Sanders Louisiana Department of Justice − B.R. P.O. Box 94005 1885 North Third Street Baton Rouge, LA 70804−9005 225−326−6300 Fax: 225−326−6192 Email: sandersd@ag.state.la.us LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 3:15-cv-567 As of: 09/20/2015 12:44 PM CDT 2 of 4

Defendant
Jeffrey F. Wiley In His Official Capacity as Ascension Parish Sheriff

represented by Lloyd Frederick Schroeder Usry, Weeks &Matthews 1615 Poydras Street Suite 1250 New Orleans, LA 70112 504−592−4600 Fax: 504−592−4641 Email: fschroeder@uwmlaw.com ATTORNEY TO BE NOTICED

Date Filed 08/25/2015
08/25/2015 08/26/2015 08/26/2015
08/26/2015 08/26/2015 08/26/2015 08/26/2015 08/26/2015 08/26/2015

# Docket Text
1 COMPLAINT against All Defendants ( Filing fee $ 400 receipt number 053N−1280118.), filed by Rebecca M Snow. (Attachments: # 1 Attachment Civil Cover Sheet, # 2 Attachment Summons, Lambert, # 3 Attachment Summons, Wiley, # 4 Exhibit Exhibit Declaration, # 5 Exhibit Exhibit Bail Schedule)(Schwartzmann, Katharine) Modified on 8/26/2015 to replace and flatten summons (LLH). Modified on 8/26/2015 to replace the main document in accordance with 14 (NLT). (Entered: 08/25/2015)
2 MOTION to Certify Class by Rebecca M Snow. (Attachments: # 1 Memorandum in Support, # 2 Exhibit Quigley Declaration, # 3 Exhibit Schwartzmann Decl., # 4 Exhibit Foley Decl., # 5 Exhibit Karakatsanis Decl.)(Schwartzmann, Katharine) (Entered: 08/25/2015)
3 MOTION for Alec Karakatsanis to Appear Pro Hac Vice (Filing fee $100.00, Receipt Number 053N−1280313) by Rebecca M Snow. (Attachments: # 1 Attachment Certificate of Good Standing, # 2 Proposed Pleading; Proposed Order)(Schwartzmann, Katharine) (Entered: 08/26/2015)
4 MOTION for Temporary Restraining Order and Preliminary Injunction against Defendant Wiley by Rebecca M Snow. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading; Order, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit)(Schwartzmann, Katharine) . Modified on 8/26/2015 to replace the main document in accordance with record document 8 (NLT). Modified on 8/26/2015 to edit text and add motion(LLH). (Entered: 08/26/2015)
5 MOTION for Leave to Exceed Page Limit by Rebecca M Snow. (Attachments: # 1 Proposed Pleading; Order, # 2 Proposed Pleading; Proposed Memorandum)(Schwartzmann, Katharine) Modified on 8/26/2015 to edit text (LLH). (Entered: 08/26/2015)
6 MOTION to Substitute Docket Entry by Rebecca M. Snow. (Attachments: # 1 Proposed Pleading; Proposed Order, # 2 Proposed Pleading;)(Schwartzmann, Katharine) Modified on 8/26/2015 to edit text (LLH). (Entered: 08/26/2015)
7 Notice to Counsel regarding 5 Motion for Leave to File Excess Pages. At the direction of the Court, the motion is granted. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/26/2015)
8 Notice to Counsel regarding 6 Motion to Substitute Docket Entry. At the direction of the Court, the motion is granted and the Clerk of Court is directed to substitute the corrected pleading. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/26/2015)
9 First MOTION Substitution/correction of caption on first page of Complaint. by Rebecca M. Snow. (Attachments: # 1 Exhibit, # 2 Proposed Order)(Foley, Eric) (Entered: 08/26/2015)
10 Summons Issued as to Marilyn M. Lambert, Jeffrey F. Wiley. (NOTICE: Counsel shall print and serve both the summons and all attachments in accordance with Federal Rule of Civil Procedure 4.) (LLH) (Entered: 08/26/2015)

Case: 3:15-cv-567 As of: 09/20/2015 12:44 PM CDT 3 of 4

08/26/2015 08/26/2015 08/26/2015 08/26/2015
08/26/2015 08/27/2015 08/27/2015 08/27/2015 08/27/2015 08/27/2015

MOTION(S) REFERRED: 9 First MOTION Substitution/correction of caption on first page of Complaint. , 3 MOTION for Alec Karakatsanis to Appear Pro Hac Vice (Filing fee $100.00, Receipt Number 053N−1280313). This motion is now pending before the USMJ. (LLH) (Entered: 08/26/2015)
11 Second MOTION to Substitute First Page of Plaintiffs' Complaint by Rebecca M. Snow. (Attachments: # 1 Attachment Proposed correction to Complaint's caption, # 2 Attachment Proposed Order)(Foley, Eric) Modified to edit text on 8/27/2015 (BCL). (Entered: 08/26/2015)
12 Notice to Counsel regarding 9 Motion to Substitute. At the direction of the Court, the motion is granted and the Clerk of Court is directed to substitute the document. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/26/2015)
13 ORDER regarding 4 MOTION for Temporary Restraining Order and MOTION for Preliminary Injunction filed by Rebecca M. Snow : IT IS ORDERED that a telephone status conference will be held on Thursday, August 27, 2015, at 2:30 p.m. Counsel for Plaintiff shall initiate the conference call to chambers. IT IS FURTHER ORDERED that a hearing on the Motion for Temporary Restraining Order and Preliminary Injunction will be held in Courtroom 3 on Friday, August 28, 2015 at 10:00 a.m. IT IS FURTHER ORDERED that Plaintiffs counsel shall notify and serve a copy of this order on Defendants or counsel for Defendants, if known. Signed by Judge Shelly D. Dick on 8/26/15. (DCB) (Entered: 08/26/2015)
14 Notice to Counsel regarding 11 Second Motion to Substitute First Page of the Complaint. At the direction of the Court, the motion is granted and the Clerk of Court is directed to substitute the corrected pleading. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/26/2015)
15 ORDER granting 3 Motion for Alec George Karakatsanis to Appear Pro Hac Vice. Signed by Magistrate Judge Richard L. Bourgeois, Jr. on 8/27/2015. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (JSL) (Entered: 08/27/2015)
16 MOTION to Enroll David G. Sanders as Attorney by Marilyn M. Lambert. (Sanders, David) (Entered: 08/27/2015)
17 Notice to Counsel regarding 16 Motion to Enroll as Attorney. At the direction of the Court, the motion is granted. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/27/2015)
18 Notice to Counsel: The hearing regarding the 4 Motion for Temporary Restraining Order set for 8/28/15 is cancelled. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/27/2015)
19 Notice to Counsel: Hearing regarding the 4 Motion for Preliminary Injunction is set for 9/1/2015 at 09:30 AM in Courtroom 3 before Judge Shelly D. Dick.

Evidence, in electronic format, shall be provided in accordance with Local Rule 79 and Administrative Procedures.

08/27/2015 08/27/2015

(This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.)(DCB) (Entered: 08/27/2015)
20 NOTICE of Briefing Schedule on 4 MOTION for Preliminary Injunction : Opposition to the motion shall be filed by noon on 8/31/15.(This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/27/2015)
21 MOTION to Enroll Fred Schroeder as Counsel of Record by Jeffrey F. Wiley. (Attachments: # 1 Proposed Pleading;)(Schroeder, Lloyd) Modified on 8/28/2015 to edit text(LLH). (Entered: 08/27/2015)

Case: 3:15-cv-567 As of: 09/20/2015 12:44 PM CDT 4 of 4

08/27/2015 08/27/2015
08/28/2015 08/28/2015 09/02/2015 09/02/2015 09/02/2015 09/03/2015

22 ORDER granting 21 Motion to Enroll as Attorney.. Signed by Judge Shelly D. Dick on 8/27/15. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 08/27/2015)
23 ORDER granting 4 MOTION for Temporary Restraining Order: Accordingly, is HEREBY ORDERED that: 1. The Motion for Temporary Restraining Order (Rec. Doc. 4) is hereby GRANTED insofar as Sheriff Wiley is ORDERED to release Rebecca M. Snow immediately, either on her own recognizance or subject to an unsecured bond or other reasonable and lawful non−financial conditions. 2. The Motion for Temporary Restraining Order (Rec. Doc. 4) is hereby DENIED in all other respects. 3. A hearing to determine whether to convert this temporary restraining order into a preliminary injunction is set for an evidentiary hearing on Tuesday, September 1, 2015 at 9:30am in Courtroom 3. Signed by Judge Shelly D. Dick on 8/27/15. (DCB) (Entered: 08/27/2015)
24 Joint MOTION to Continue Hearing on Preliminary Injunction by Rebecca M. Snow. (Attachments: # 1 Proposed Pleading; Order)(Schwartzmann, Katharine) (Entered: 08/28/2015)
25 ORDER granting 24 Motion to Continue: Evidentiary Hearing RESET for 9/3/2015 at 09:30 AM in Courtroom 3 before Judge Shelly D. Dick. Defendants' Memorandum in Opposition to Plaintiff's Motion is now due to be filed into the record of these proceedings by 9/2/15 at 12:00 p.m. Signed by Judge Shelly D. Dick on 8/28/15. (DCB) (Entered: 08/28/2015)
26 Opposition to Preliminary Injunction filed by Marilyn M. Lambert. (Sanders, David) Modified to edit text on 9/2/2015 (BCL). (Entered: 09/02/2015)
27 Joint MOTION for Settlement Agreement and Joint Stipulation of Dismissal by All Plaintiffs. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading; Order, # 3 Exhibit Proposed Settlement Agreement)(Schwartzmann, Katharine). Added MOTION to Dismiss on 9/2/2015 to edit text(ELW). (Entered: 09/02/2015)
28 Notice to Counsel: The Evidentiary Hearing set for Thursday, September 3, 2015 at 9:30 a.m. is CANCELLED. (This is a TEXT ENTRY ONLY. There is no hyperlink or PDF document associated with this entry.) (DCB) (Entered: 09/02/2015)
29 ORDER granting 27 Motion for Settlement and Joint Stipulation of Dismissal. The Parties to the Settlement Agreement attached to this Order are to comply with the terms of the agreement. IT IS FURTHER ORDERED that the Plaintiff's claims are dismissed with prejudice subject only to the further jurisdiction of this Court to enforce the terms of the settlement agreement. Signed by Judge Shelly D. Dick on 9/3/2015. (Attachments: # 1 Settlement Agreement) (BCL) (Entered: 09/03/2015)