Smith-Thomas Settlement: Texas Over-Detention, Coverage and Payouts

The Hughes v. Smith County settlement is a $1.5 million class action resolution, approved by a federal judge in February 2026, that compensates more than 100 people who were held in the Smith County, Texas jail past the dates they were legally entitled to be released. Payments go to people convicted of felonies who finished their sentences at the jail between July 11, 2021, and December 31, 2024, and were not released within two days of completing them.¹

Who the Settlement Covers

The class includes anyone detained at the Smith County Jail between July 11, 2021, and December 31, 2024, who was convicted of a felony, completed their sentence at the jail, and was not released within two days of finishing it. Open records requests identified at least 102 people who fit the pattern, with 105 total instances of over-detention during that window; the gap reflects individuals who were over-detained more than once.²

The case was filed on July 11, 2023, in the United States District Court for the Eastern District of Texas, Tyler Division, as Hughes et al. v. Smith County, Texas, Case No. 6:23-cv-344-JDK, under 42 U.S.C. § 1983.³ U.S. District Judge Jeremy D. Kernodle granted final approval on February 18, 2026, following a hearing on February 5.¹ Class members who accept payment waive other claims against the county tied to their over-detention during the covered period. Smith County did not admit any wrongdoing or liability, and the Texas Association of Counties funded the settlement.⁴

How the Money Is Divided

The $1.5 million is split into two pots.

$1 million goes to class members. Each person’s payment is calculated by the number of extra days they spent in custody, with eligible class members receiving a minimum of roughly $685 per day of compensable detention.⁵
$500,000 covers attorney’s fees, litigation expenses, administration costs, and $5,000 incentive awards for each of the three named plaintiffs.⁶

The plaintiffs were represented by Loevy & Loevy, the Deason Criminal Justice Reform Center at SMU, and civil rights attorney Akeeb Dami Animashaun.⁷

Why People Were Held Past Their Release Dates

The bottleneck was the “pen packet,” the paperwork a Texas county jail must compile and send to the Texas Department of Criminal Justice before a sentenced inmate can be released or transferred to state prison. Smith County used what the lawsuit called an “inadequate, disjointed, paper-based system” that routinely took days or weeks to complete. Once TDCJ receives a finished packet, it usually signs off on release the same day. In Smith County, understaffing and disorganization meant the packets sat unfinished.¹ Plaintiffs’ attorneys found cases where jail employees took at least 12 days just to retrieve the necessary documents from the clerk’s office.⁸

According to the Texas Jail Project, jail staff also insisted that inmates had to be physically transferred to TDCJ before release, even after they had already served their court-ordered sentences. The organization noted that no such requirement exists in Texas law.²

Many of those affected came off the state’s forensic waitlist, a backlog of defendants found incompetent to stand trial who wait in county jails for transfer to a state hospital for competency restoration. After being restored and accepting plea deals, they had often already served more time than their sentences required. The jail still would not release them.²

What Happened to the Named Plaintiffs

Lead plaintiff LaDarion Hughes was found incompetent to stand trial in September 2020 and spent time on the forensic waitlist before being restored and accepting a two-year plea deal on December 16, 2021. By that day he had already been in custody for 911 days, well past the sentence he agreed to.² The jail still held him for 27 additional days. According to Krish Gundu of the Texas Jail Project, “He needed help because the jail was refusing to release him. Nobody would listen to him, nobody would — including his court appointed attorney.” A call from the Texas Jail Project to a state representative finally secured his release in January 2022.⁹

Angela Alonzo was held 33 days after receiving a time-served sentence on March 18, 2022. She filed two or three grievances a week demanding release, starting the day after sentencing, and received no response. Jail staff told her they were “busy because the Jail was under investigation.” Her mother and child waited outside the jail for eight hours on sentencing day.¹⁰

Demarcus Lively was held eight days past his entitled release date of October 13, 2022. His grievances came back marked as “not a grievable issue.” When his family called the jail, staff said they could not find him in the system. TDCJ told the family it had already approved his release and that the delay was the jail’s.¹⁰

What the Settlement Does Not Do

The agreement did not require Smith County to adopt any specific policy reforms. The county has said it put new processes in place, but plaintiffs’ attorneys said one of their clients was held for 33 extra days even after the jail reportedly moved to an electronic pen packet system.⁸ In July 2025, Dalila Reynoso, lead mental health advocate for the Texas Jail Project, told the Smith County Commissioners Court that over-detention violations were still occurring.²

The settlement covers only over-detentions between July 2021 and December 2024. It does not foreclose lawsuits over incidents outside that window. Gundu said the lack of any admission limits what the resolution can accomplish: “Accountability is impossible to get when there is no admission of wrongdoing, and unless there is admission of wrongdoing, you can’t begin to have the conversation about how to repair.”¹¹

1
Prison Legal News. $1.5 Million Class Action Settlement Reached in Texas Jail Over-Detention Case
2
Texas Jail Project. Advocacy Leads to Unprecedented $1.5 Million Settlement in Federal Lawsuit Against Smith County
3
CourtListener. Hughes v. Smith County Docket
4
Texas Jail Project. Weekly News Round-Up 7-7-25
5
Smith County Settlement. Hughes v. Smith County Class Action Settlement
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Smith County Settlement. Hughes v. Smith County Settlement FAQ
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CourtListener. Hughes v. Smith County Parties
8
KLTV. Smith County Settles Lawsuit Over Inmates Held Past Release Dates
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KERA News. People Kept in East Texas Jail Past Release Date Settle Lawsuit for $1.5 Million
10
University of Michigan Civil Rights Litigation Clearinghouse. Hughes v. Smith County Complaint
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Texas Tribune. Texas Jail Oversentencing Dallas Smith Counties