Collins v. Daniels

This case was brought pursuant to 42 U.S.C. 1983, challenging the constitutionality of New Mexico’s system of bail. Plaintiffs-Appellants Darlene Collins, the Bail Bond Association of New Mexico (“BBANM”), and five New Mexico state legislators (the “Legislator Plaintiffs”) alleged New Mexico’s system of bail violated the Excessive Bail Clause of the Eighth Amendment, as well as the procedural and substantive components of the Due Process Clause of the Fourteenth Amendment. Plaintiffs further alleged the rules governing New Mexico’s system of bail were promulgated by the New Mexico Supreme Court in violation of the New Mexico Constitution. Defendants-Appellees were the New Mexico Supreme Court and its justices; the Second Judicial District Court of New Mexico, its chief judge, and its court executive officer; and the Bernalillo County Metropolitan Court, its chief judge, and its court executive officer. They moved to dismiss, arguing that Plaintiffs lacked standing, Defendants were immune from suit, and Plaintiffs failed to state a claim. Defendants also moved for Rule 11 sanctions on the basis that Plaintiffs’ attorneys filed suit without adequately researching the viability of Plaintiffs’ claims. Plaintiffs moved for leave to amend their complaint to add a claim that Defendants’ Rule 11 motion violated Plaintiffs’ First Amendment rights. The district court granted Defendants’ motion to dismiss because it found that BBANM and the Legislator Plaintiffs lacked standing, Defendants were immune from suit, and Plaintiffs failed to state a claim. The district court also granted Defendants’ motion for sanctions and denied Plaintiffs’ motion to amend. Plaintiffs timely appealed, but finding no reversible error in the district court's judgment, the Tenth Circuit affirmed. View "Collins v. Daniels" on Justia Law