This proposed class action presents a constitutional challenge to the bail practices of the state court in Leon County, Florida. The record would support a finding that the court routinely sets unaffordable bail with the effect, and sometimes with the purpose, of detaining a defendant pending trial. The court set unaffordable bail for Brittany Knight.
Ms. Knight filed this petition for a writ of habeas corpus under 28 U.S.C. § 2241. The respondent is the Sheriff of Leon County—the official in whose custody Ms. Knight was held when she filed this action.
Ms. Knight seeks to represent a class of individuals detained on unaffordable bail in Leon County. Pending are cross-motions for summary judgment. Also pending is a motion to certify the class.
The claim that some of the proposed class members are being detained unconstitutionally is strong. But Ms. Knight herself is not entitled to relief for two reasons. First, any constitutional violation she suffered had been remedied or no longer had any effect by the time she filed this petition. Ms. Knight was not entitled to relief on her individual claim when she filed it. Second, Ms. Knight entered a nolo contendere plea five days after she filed this petition and is serving the agreed prison sentence. Her individual claim is moot.
That a named plaintiff’s individual claim becomes moot does not, without more, deprive the named plaintiff of standing to pursue class claims. But Ms. Knight’s claim was unfounded when she filed it. The claim is not typical of the class claims, and she is not an adequate class representative. This order denies her motion to certify a class. Absent class certification, Ms. Knight’s individual claim must be dismissed as moot, ending the case.
The plaintiff Brittany Knight’s claims against the defendant Sheriff of Leon County, Florida are dismissed as moot.
JESSICA J. LYUBLANOVITS CLERK OF COURT
April 1, 2019 s/Betsy Breeden
DATE Deputy Clerk: Betsy Breeden