CHESTER DYSON, PETITIONER,
v.
LARRY CAMPBELL, SHERIFF OF LEON COUNTY, FLORIDA, RESPONDENT
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Chester Dyson seeks habeas corpus relief contending that the $25,000 and $10,000 bonds set for his burglary and robbery charges are effectively no bond due to his inability to pay them. The court denies relief, holding that a defendant's inability to meet a bond amount does not automatically make the bond excessive, and that trial courts must consider multiple statutory factors beyond the defendant's financial capacity.
The court denied habeas corpus relief, holding that a defendant's mere inability to meet a bond amount does not automatically render the bond excessive or unreasonable. The court must consider multiple statutory factors under Florida law, and reasonable conditions of release do not necessarily mean conditions the defendant can afford to meet.
[1] A trial court must consider factors beyond a defendant's financial resources when determining appropriate pretrial release conditions.
[2] A bond amount is not per se excessive or unreasonable merely because a defendant testifies that they cannot afford to meet it.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the setting of an excessive bond is the functional equivalent of setting no bond at all, and that the remedy of habeas corpus relief lies in such a circumstance”
Establishes the legal principle that habeas relief is available for truly excessive bonds
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Join FLexlaw to unlock all legal intelligenceDyson was charged with burglary of a dwelling with person assaulted (first-degree felony) and robbery (second-degree felony). His initial bond was set…
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PER CURIAM.
Chester Dyson seeks habeas corpus relief, alleging that in light of his financial circumstances, the pretrial bond amount set by the circuit court is tantamount to no bond at all. We deny the petition on the merits.
Dyson is charged by information with burglary of a dwelling with person assaulted, a first degree felony punishable by life, and robbery, a second degree felony. At first appearance, his bond was set at $50,000. On Dyson’s motion, that bond was subsequently reduced to $25,000 for the burglary charge and $10,000 for the robbery charge. Despite the trial court’s decision to reduce his bond, Dyson claims an entitlement to habeas corpus relief because his financial resources are not such that he can satisfy even the reduced bond amount.
We are well aware of the body of case law essentially holding that the setting of an excessive bond is the functional equivalent of setting no bond at all, and that the remedy of habeas corpus relief lies in such a circumstance. See, e.g., Good v. Wille, 382 So. 2d 408 (Fla. 4th DCA 1980). It does not follow, however, that where a defendant testifies that he cannot meet a given bond amount, that bond is per se excessive or unreasonable. In addition to a defendant’s financial resources, a trial court must consider a host of other factors in determining whether to release the defendant on bail or other conditions, and if so, what bail or other conditions are appropriate. See Fla. R.Crim. P. 3.131; § 903.046, Fla. Stat. (2005). In this case, few if any of those factors weigh in petitioner’s favor, and insofar as it relates to monetary conditions, we decline to adopt petitioner’s view that “reasonable conditions” of pretrial release necessarily means conditions that the defendant can reasonably meet.
We are satisfied based on our review of the record that the trial judge in this case made a conscientious and reasoned decision concerning the appropriate conditions of pretrial release. In doing so, the trial judge neither committed legal error nor abused her discretion. Accordingly, the petition for writ of habeas corpus is denied.
PETITION DENIED.
BARFIELD, WOLF and BROWNING, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (12 total)
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Mehaffie v. John Rutherford as Sheriff of Duval Cnty., 143 So. 3d 432 (Fla. 1st DCA 2014)…s of the trial court’s order.” Robinson v. State, 95 So. 3d 437, 438 (Fla. 5th DCA 2012). Simply because a defendant testifies that he cannot meet a given bond amount does not mean the bond is per se excessive or unreasonable. See Dyson v. Campbell, 921 So. 2d 692, 693 (Fla. 1st DCA 2006). Further, “[i]n addition to a defendant’s financial resources, a trial court must consider a host of other factors in determining whether to release the defendant on bail or other conditions, and if so, what bail or other co…
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Cepero v. Mascara, 981 So. 2d 671 (Fla. 4th DCA 2008)…in the record before this court, may justify a higher bond, the same bond, or additional conditions and requirements. However, the state presented no evidence at the hearing below supporting the amount set by the trial court. See Dyson v. Campbell, 921 So. 2d 692 (Fla. 1st DCA 2006) (explaining that petitioner’s inability to post a certain bond amount does not render that amount per se unreasonable and trial court must consider many other factors in deter [*673] mining what conditions for pretrial release ar…
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Knight v. State, 213 So. 3d 1019 (Fla. 1st DCA 2017)…o. 3d 813, 813 (Fla. 5th DCA 2014) (granting petition, ordering further consideration, and requiring “appropriate findings in the order,” after concluding it was unclear whether the trial court considered the proper factors), with Dyson v. Campbell, 921 So. 2d 692, 693 (Fla. 1st DCA 2006) (approving bond reduction after concluding the trial court “made a conscientious and reasoned decision concerning the appropriate conditions of pretrial release”). Nevertheless, Knight cannot satisfy her burden by just show…
Previewing 3 of 12 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Finlason v. Finlason, 382 So. 2d 408 (Fla. 4th DCA 1980)
- Good v. Wille, 382 So. 2d 408 (Fla. 4th DCA 1980)