The following excerpt is from Sanders v. Grimes, Case No. 1:18-cv-01285-AWI-JLT (PC) (E.D. Cal. 2020):
defendant fails to appear for a court hearing or "[a]ny other occasion ... if the defendant's presence in court is lawfully required." Id. 1305. In other words, whether a criminal defendant's previously posted bond is forfeited is a separate matter from whether the defendant is granted bail pending an appeal. Plaintiff does not explain how the failure to file a notice of appeal caused the forfeiture of bond he posted at the beginning of his criminal proceedings. In any event, such forfeiture would not be foreseeable. See Hines v. United States, 60 F.3d 1442, 1450 (9th Cir. 1995) ("The question of proximate cause is usually defined with reference to the scope of the foreseeable risks of the actor's conduct.").
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