Stack v. Boyle
Citation
342 U.S. 1 (1951)
Facts
Twelve defendants were indicted for conspiring to violate the Smith Act (advocating overthrow of the government) based on their Communist Party membership. The government set bail at 50,000 figure.
Issue
Does the Eighth Amendment’s prohibition on excessive bail require that bail be set at an individualized amount reasonably necessary to ensure the defendant’s presence at trial?
Holding
Yes. The Supreme Court held that the $50,000 bail was excessive because it was not set at a figure reasonably calculated to ensure appearance at trial. Setting bail in a predetermined group amount, without individualized findings, violates the Eighth Amendment.
Rule / Doctrine
Constitutional bail standard: bail must not exceed the amount reasonably necessary to ensure the defendant’s presence at trial. Bail set higher than this amount is “excessive” under the Eighth Amendment. Bail must be individualized — courts cannot set uniform bail based on offense category or group membership without considering the specific defendant’s circumstances.
Significance
Stack v. Boyle establishes the foundational constitutional limit on bail as a tool for ensuring appearance, not punishment. It must be read alongside United States v. Salerno (1987), which upheld the Bail Reform Act’s preventive detention provisions, holding that detention based on dangerousness — as distinct from excessive bail — can be constitutional when procedurally rigorous.