Bail Clause, the Excessive Fines Clause and the Cruel and Unusual Punishment Clause together form a shield against abuses stemming from the government’s punitive or criminal-law-enforcement authority. Excessive bail In England, sheriffs originally determined whether to grant bail to criminal suspects. Since they tended to abuse their power, Parliament passed a statute in 1275 whereby bailable and non-bailable offenses were defined. The King's judges often subverted the provisions of the law. It was held that an individual may be held without bail upon the Sovereign's command. Eventually, the Petition of Right of 1628 argued that the King did not have such authority. Later, technicalities in the law were exploited to keep the accused imprisoned without bail even where the offenses were bailable; such loopholes were for the most part closed by the Habeas Corpus Act 1679. Thereafter, judges were compelled to set bail, but they often required impracticable amounts. Finally, the English Bill of Rights (1689) held that "excessive bail ought not to be required." However, the English Bill of Rights did not determine the distinction between bailable and non-bailable offenses. Thus, the Eighth Amendment has been interpreted to mean that bail may be denied if the charges are sufficiently serious. The Supreme Court has also permitted "preventive" detention without bail. In United States v. Salerno, , the Supreme Court held that the only limitation imposed by the Excessive Bail Clause is that "the government's proposed conditions of release or detention not be 'excessive' in light of the perceived evil". In Stack v. Boyle, , the Supreme Court declared that a bail amount is "excessive" under the Eighth Amendment if it were "a figure higher than is reasonably calculated" to ensure the defendant's appearance at trial. The incorporation status of the Excessive Bail Clause is unclear. In Schilb v. Kuebel, 404 U.S. 357 (1971), the Court stated in dicta: "Bail, of course, is basic to our system of law, and the Eighth Amendment's proscription of excessive bail has been assumed to have application to the States through the Fourteenth Amendment." In McDonald v. City of Chicago (2010), the right against excessive bail was included in a footnote listing incorporated rights. Excessive fines Waters-Pierce Oil Co. v. Texas In Waters-Pierce Oil Co. v. Texas, , the Supreme Court held that excessive fines are those that are "so grossly excessive as to amount to a deprivation of property without due process of