In Ex parte Singleton, 2004 WL 2676659 (Ala. Crim. App. November 24, 2004) the trial court set a $150,000 “cash only” bond. The defendant appealed arguing that under the Alabama Constitution he had a right to bail with “sufficient sureties” and that the cash only bail was excessive and in violation of the sufficient sureties clause (Ala. Const. Art. I, §16). The Court reviewed the derivation of the clause and decisions from other states with similar clauses, and held that the cash only bail was constitutional and that the amount was not excessive given the facts of the case. The Court reasoned that “sufficient” was a limitation on a defendant’s access to sureties and gave discretion to the judicial officer setting bail.