Hayes v. Faulkner County, Ark.

• Position: PRETRIAL DETENTION - Brief Article

U.S. Appeals Court

ACCESS TO COURTS

SPEEDY TRIAL

Hayes v. Faulkner County, Ark., 388 F.3d 669 (8th Cir. 2004). An arrestee brought a [section] 1983 action against a county, sheriff and jail administrator, stemming from his 38-day detention prior to an initial court appearance. The district court entered judgment in favor of the arrestee and the defendants appealed. The appeals court affirmed. The court held that the county's detention policy was deliberately indifferent to the substantive due process rights of the arrestee and that the 38-day detention of the arrestee shocks the conscience. The county's detention policy involved the sheriff's office submitting names of those confined in jail to the court, and then waiting for the court to schedule a hearing. The court found that the policy improperly delegated the responsibility of bringing arrestees promptly to court for first appearance, and ignored the lack of authority for long-term confinement. The court held that the jail administrator was deliberately indifferent because he...