Trujillo v. State

Summary

The Arkansas Supreme Court denied Ramon B. Trujillo’s petition for a writ of certiorari challenging the circuit court’s imposition of $300,000 cash-only bail. The court held that cash-only bail is permissible under article 2, section 8 of the Arkansas Constitution and Arkansas Rule of Criminal Procedure 9.2, while concluding that Trujillo’s excessive-bail claim was moot after his guilty plea. Chief Justice Brill and Justice Hart dissented.

Holdings

1. Although Trujillo's individual bail dispute had become moot, the court would review the cash-only-bail issue under the exception for questions of substantial public interest.
2. The Arkansas Constitution permits cash-only bail because the phrase "sufficient sureties" encompasses a broad range of methods of assuring the defendant's appearance, including cash, when bail is set pursuant to Arkansas Rule of Criminal Procedure 9.2.
3. The court did not reach the excessive-bail challenge because Trujillo's guilty plea rendered that individualized issue moot.

Questions Presented

1. Whether Arkansas Constitution article 2, section 8 permits a court to impose cash-only bail.
2. Whether the $300,000 bail amount was excessive.
3. Whether the petition for writ of certiorari could be considered after Trujillo pleaded guilty and the bail controversy became moot.

Disposition

writ_denied