People ex rel. Shapiro v. Keeper of City Prison, 296 N.Y. 463 (1947)
A writ of habeas corpus is available to protect against excessive bail, but relief is granted only to prevent invasion of constitutional rights, not merely due to a difference of opinion regarding the amount of bail.
Summary
This case addresses the issue of excessive bail and the use of a writ of habeas corpus to challenge it. The relators sought relief from what they considered excessive bail fixed at $250,000. The New York Court of Appeals affirmed the lower court’s decision, finding that considering the seriousness of the crime (murder), the relators’ backgrounds, their relationship to potential witnesses, and the risk of flight, the bail amount was not excessive as a matter of law. The court emphasized that the reasonableness of bail depends on the specific facts of each case.
Facts
The relators were being held in connection with a murder investigation. The judge of the Court of General Sessions fixed bail for each relator at $250,000. The prosecution presented evidence regarding the seriousness of the crime, the relators’ criminal records, their relationships to other individuals involved, and the possibility they might flee to avoid testifying.
Procedural History
The relators sought a writ of habeas corpus, arguing that the bail amount was excessive. The lower court denied the writ. The relators appealed to the New York Court of Appeals.
Issue(s)
Whether, given the facts presented, the bail amount of $250,000 fixed by the Court of General Sessions was excessive as a matter of law, thereby warranting relief through a writ of habeas corpus.
Holding
No, because considering the seriousness of the crime under investigation, the character, reputation, background, and extensive criminal records of the relators, their relationship to others against whom they may be called to testify, the possibility of flight to avoid giving testimony, and the difficulty of procuring their return if they leave the State, the bail amount was not excessive as a matter of law.
Court’s Reasoning
The Court of Appeals stated that a writ of habeas corpus is the proper mechanism to challenge excessive bail as a violation of constitutional rights. However, the court emphasized that the decision to grant relief depends on whether the bail is excessive as a “matter of law,” not merely a difference of opinion. The court considered several factors to determine the reasonableness of the bail: the seriousness of the crime (murder), the relators’ criminal histories, their relationships to potential witnesses, and the risk of flight. The court found sufficient evidence before the lower court to justify the high bail amount, given these factors. The court distinguished this case from People ex rel. Lobell v. McDonnell, noting that the evidence presented in this case regarding the relevant factors was not present in Lobell. The court stated, “the reasonableness of bail in any case depends upon examination of the particular record. Evidence such as was here adduced was not there furnished.” The court affirmed the order without prejudice to any future proceedings where the relators might raise the issue of undue or prolonged detention.