UNITED STATES OF AMERICA,

v.
[DEFENDANT NAME],

Defendant.

Criminal Case No.: [CRIM. NO. xxxx–xxxx]
Judge: Hon. [JUDGE NAME]
Next Scheduled Hearing: [DATE]

MOTION FOR REDUCTION OF BAIL AND IMPOSITION OF REASONABLE CONDITIONS OF RELEASE

[Counsel for Defendant], pursuant to D.C. Code §§ 23-1321, 23-1322, and 23-1323, and Superior Court Criminal Rule 46, respectfully moves this Court to (i) reduce the current bail amount of $[CURRENT BAIL] to $[REQUESTED BAIL] or (ii) in the alternative, release Defendant on non-financial conditions that will reasonably assure appearance and community safety. In support, Defendant states as follows:

[// GUIDANCE: Replace bracketed text throughout with client-specific information; delete any provisions that do not fit case facts.]

TABLE OF CONTENTS

I. Preliminary Statement ............................................. 2
II. Statement of Facts & Procedural Posture ........................... 2
III. Applicable Legal Standards ........................................ 3
IV. Argument .......................................................... 4
   A. Statutory Bail Factors (D.C. Code § 23-1321(c)) ................. 4
   B. Change in Circumstances (D.C. Code § 23-1323) .................. 5
   C. Least-Restrictive Alternatives to Monetary Bail ................. 6
V. Proposed Conditions of Release .................................... 7
VI. Prayer for Relief ................................................. 8
VII. Certificate of Service ........................................... 9
Exhibit A – Proposed Order ........................................... 10

I. PRELIMINARY STATEMENT

1. Defendant, [FULL LEGAL NAME] (“Defendant”), is presently detained at [FACILITY] following the initial appearance on [DATE], at which the Court imposed a secured financial bond in the amount of $[CURRENT BAIL].

2. Since the setting of that bond, material circumstances have changed and new information has become available that warrants reconsideration and reduction of bail pursuant to D.C. Code § 23-1323(a).

3. Defendant respectfully submits that continued detention on the current financial conditions is unsupported by the statutory factors, is more restrictive than necessary to achieve the purposes of pretrial release, and imposes an undue hardship that is inconsistent with D.C. law and constitutional principles.

II. STATEMENT OF FACTS & PROCEDURAL POSTURE

4. On [DATE], Defendant was arrested and charged by complaint/information/indictment with [CHARGES] in violation of [CITATION TO STATUTE(S)].

5. At the initial appearance, the Government requested a secured bond; the Court set bail at $[CURRENT BAIL] with additional conditions of [CONDITIONS, if any].

6. Since that time, Defendant has:
   a. Secured stable employment at [EMPLOYER/ROLE];
   b. Arranged permanent housing at [ADDRESS]; and
   c. Enrolled in [TREATMENT/PROGRAM], demonstrating commitment to rehabilitation.

7. Defendant has no prior failures to appear, has longstanding ties to the District of Columbia, and poses no flight risk or threat to community safety.

III. APPLICABLE LEGAL STANDARDS

8. Under D.C. Code § 23-1321(b), a judicial officer shall order the pretrial release of a person on personal recognizance or unsecured appearance bond unless such release will not reasonably assure the person’s appearance or will endanger the safety of any other person or the community.

9. If personal recognizance is insufficient, the Court must impose the least restrictive additional conditions necessary to mitigate identified risks, in the priority order set forth in § 23-1321(c).

10. Detention or high financial conditions may be imposed only when no combination of enumerated conditions will reasonably assure appearance and safety. See § 23-1322(b).

11. Pursuant to § 23-1323(a), the Court may reopen a bail determination upon a showing that information exists that was not known at the time of the prior hearing and that has a material bearing on the release decision.

IV. ARGUMENT

A. Statutory Bail Factors (D.C. Code § 23-1321(c))

12. Nature and Circumstances of the Offense (§ 23-1321(c)(1)):
    The charged offenses are non-violent and do not involve allegations of weapon possession or threats of violence.

13. Weight of the Evidence (§ 23-1321(c)(2)):
    The Government’s case rests primarily on [TYPE OF EVIDENCE—e.g., circumstantial testimony, surveillance video of limited clarity], which is subject to challenge at trial.

14. History and Characteristics of Defendant (§ 23-1321(c)(3)):
    • Age: [AGE] years.
    • Residency: Lifelong resident of the District of Columbia.
    • Family Ties: Resides with and financially supports [FAMILY MEMBERS].
    • Employment: Employed full-time at [EMPLOYER] since [DATE].
    • Criminal History: [No / Minor / Non-violent] prior convictions; no prior failures to appear.

15. Danger to the Community (§ 23-1321(c)(4)):
    No evidence suggests Defendant poses a threat; Pretrial Services has recommended [LEVEL OF SUPERVISION] as sufficient to address any safety concerns.

B. Change in Circumstances (D.C. Code § 23-1323)

16. Since the original bail decision, Defendant has secured verifiable employment and permanent housing, materially bolstering community ties and reducing flight risk.

17. Defendant has completed [NUMBER] weeks of [TREATMENT/COUNSELING] and can provide documentation verifying compliance and progress.

18. These developments constitute new information unknown to the Court at the time bail was set and have a direct bearing on the release assessment.

C. Least-Restrictive Alternatives to Monetary Bail

19. Non-financial conditions—such as GPS monitoring, weekly reporting to Pretrial Services, and a stay-away order from [LOCATION/PERSON]—can adequately mitigate any remaining risks.

20. Imposing a high financial bond conflicts with the statutory preference for the least-restrictive conditions and disproportionately impacts indigent defendants, raising equal-protection concerns.

V. PROPOSED CONDITIONS OF RELEASE

Defendant proposes the following graduated conditions (individually or in combination) in lieu of the current secured bond:

1. Personal recognizance or unsecured bond in the amount of $[REQUESTED BAIL OR “N/A”];
2. Weekly in-person or virtual check-ins with Pretrial Services;
3. GPS-enabled location monitoring with movement restricted to work, medical, legal, and family obligations;
4. Compliance with any treatment, counseling, or educational program as ordered;
5. No contact with alleged victims or witnesses, and stay-away from [LOCATION];
6. Surrender of passport and prohibition on obtaining new travel documents;
7. Any other condition the Court deems necessary and least restrictive.

[// GUIDANCE: Tailor conditions to specific case facts and Pretrial Services recommendations.]

VI. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully requests that this Honorable Court:

A. Reduce bail to $[REQUESTED BAIL]; or
B. Release Defendant on the non-financial, least-restrictive conditions set forth above; and
C. Grant such other and further relief as the Court deems just and proper.

Respectfully submitted,

[ATTORNEY NAME] (D.C. Bar No. [#####])
[LAW FIRM]
[ADDRESS] | [PHONE] | [EMAIL]
Counsel for Defendant

Dated: [DATE]

VII. CERTIFICATE OF SERVICE

I hereby certify that on this [DATE], a true and correct copy of the foregoing Motion for Reduction of Bail was served via [E-Filing System / Email] upon the Office of the United States Attorney for the District of Columbia, Attn: [AUSA NAME].

[ATTORNEY NAME]

Exhibit A – [PROPOSED] ORDER

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
Criminal Division

UNITED STATES OF AMERICA,

v.
[DEFENDANT NAME],

Defendant.

Criminal Case No.: [CRIM. NO. xxxx–xxxx]

[PROPOSED] ORDER GRANTING MOTION FOR REDUCTION OF BAIL

Upon consideration of Defendant’s Motion for Reduction of Bail, the Government’s opposition thereto, the Pretrial Services report, and the entire record herein, it is this ___ day of _, 20_, hereby

ORDERED that the Motion is GRANTED; and it is further

[Select One]
☐ ORDERED that bail is reduced to $[REQUESTED BAIL], secured/unsecured as follows: _____; or
☐ ORDERED that Defendant is released on personal recognizance subject to the following conditions, deemed sufficient to reasonably assure appearance and community safety:

1. Weekly reporting to Pretrial Services;
2. GPS location monitoring;
3. [ADDITIONAL CONDITIONS];
4. No new arrests and compliance with all laws; and
5. Immediate notification to the Court of any violation of the above conditions.

SO ORDERED.

Hon. [JUDGE NAME]
Judge, Superior Court of the District of Columbia

[// GUIDANCE: Review local criminal rules for signature formatting, clerk notation, and electronic filing requirements before filing. Confirm that any statutory citations remain current at time of use.]