Martinez-Brooks v. Easter (D. Conn.) - Class Action TRO Partial Grant - Expedited Discovery on PI
Class action brought on behalf of all persons incarcerated at FCI Danbury, including a subclass of those who are medically vulnerable to COVID-19. The court granted in part the motion for a TRO and issued an order that requires the Warden at FCI Danbury to adopt an accelerated process for evaluating individuals with COVID-19 risk factors for home confinement and other forms of release. The petitioners argued that the warden had not acted quickly enough to process claims for home confinement and compassionate release, therefore placing incarcerated individuals at risk given that it was not feasible to implement proper social distancing measures at the prison facility. The court granted preliminary relief on the basis that under Eighth Amendment Deliberate Indifference, confinement at the prison presented a large risk of infection and that the warden had not acted quickly enough to place incarcerated in home confinement or grant compassionate release, noting that "only 159 inmates have been reviewed since March 26, and a mere 21 inmates have actually been placed on home confinement, out of a population of roughly 1,000." The court also set a date for hearing on motion for preliminary injunction and ordered expedited discovery for the PI. § 2241 exhaustion was waived due to exception for undue prejudice caused by the delay. The PLRA did not apply to a § 2241 challenge to the fact of confinement, and since the class argued that nothing short of release would sufficiently protect them from COVID-19, that exception applied. The court did not reach the question of whether the denial of a compassionate release application would constitute res judicata barring the Eighth Amendment claims.
Martinez-Brooks v. Easter, No. 20-cv-569 (MPS) (D. Conn. May 12, 2020)
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Crowdsourced legal documents from around the country related to COVID-19 and incarceration, organized, collected, and summarized for public defenders, litigators, and other advocates. Created and managed by Bronx Defenders, Columbia Law School’s Center for Institutional and Social Change, UCLA Law COVID-19 Behind Bars Data Project, and Zealous. Mostly federal court opinions, but now expanding to states and legal filings, declarations, and exhibits.
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