Background
While released on bond for three aggravated-assault offenses, Chloe Evans fled the courthouse after a judge ordered her to remain and submit to a drug test. According to the opinion, she struck two vehicles while leaving the courthouse parking lot, led officers on a chase reaching 100 miles per hour, and ultimately crashed into other vehicles. She was injured but later left the hospital against medical advice.
Evans was then accused of evading arrest with a vehicle, aggravated assault of a public servant, and aggravated assault with a deadly weapon. Bonds on those new, not-yet-indicted charges totaled $150,000. She sought habeas relief in trial-court cause number 33364-B, arguing that the bonds were excessive and beyond her means and that her injuries could not be adequately treated in jail. She requested release on personal recognizance or a reduction in bail.
The Court’s Holding
The Tenth Court of Appeals affirmed the order denying habeas relief. Evans’s three appellate issues all rested on the assertion that the trial court had ordered her held without bond, but no no-bond order had been entered in cause number 33364-B, the case before the appellate court.
The no-bond order concerned Evans’s earlier aggravated-assault cases in cause number 15701-A. Her habeas application did not challenge that order, and she appealed only cause number 33364-B. Because the no-bond order was outside the underlying case and appeal, the court overruled her no-bond, statutory-factor, and due-process issues without deciding whether the $150,000 total bail was excessive.
Key Takeaways
- An appellate challenge to a bail ruling must concern an order entered in the trial-court case actually placed before the appellate court.
- Evans’s habeas application challenged the bonds on her new charges, not the separate no-bond order entered in her earlier aggravated-assault cases.
- The court did not reach whether the total $150,000 bail was excessive because Evans’s appellate arguments were premised on a no-bond order that was not part of the appeal.
Why It Matters
The decision underscores the importance of matching the habeas application, appellate issues, trial-court cause number, and challenged order. Even constitutional and statutory bail arguments will not be considered when they target an order outside the case on appeal.