The court granted the petitioners' motion in part, requiring the Warden to move class members designated for Residential Reentry Centers (RRCs) to instead be placed in home confinement so long as they were not convicted of a violent or sex-related offense and they did not have a "High" PATTERN score indicating a risk of recidivism. The motion was part of a class action related to the conditions endured by those incarcerated at FCI Danbury, a low security prison, as the petitioners claimed that the Warden had not made effective use of the power to grant home confinement and therefore was putting high-risk individuals at risk of contracting Covid-19. The motion came about due to the Warden utilizing RRCs rather than home confinement for a specific subset of incarcerated individuals, claiming that home confinement did provide enough supervision to this subset of class members relative to a halfway house. The court rejected this argument, noting that "inmates on home confinement are not without supervision" and are often subject to electronic monitoring; the judge also noted that "the extent to which RRCs actually present a safer environment for medically vulnerable inmates [relative to the prison] is unclear."
Martinez-Brooks v. Easter, No. 3:20-CV-00569 (MPS), 2020 WL 2813072 (D. Conn. May 29, 2020)
Criminal (Federal Charges)
Class Certification, Implementing Release Procedures, Improved Conditions, Preliminary Injunction (PI), Release, Temporary Restraining Order (TRO)
Type of Court
Federal District Court
Type of Case
Elderly, Immigrant Detention, Other, Post-Conviction Detention [jail or prison], Pre-Existing Health Conditions, Sole available caretaker for family member
Compassionate Release Case
Compassionate Release Specific Characteristics
Has a significant criminal history
Case Tracking Number
MORE CASE INFORMATION
Motions Partially Granted
Place of Incarceration
Federal Prison, Private prison
Name of Facility
Eighth Amendment - Deliberate Indifference, Substantive Due Process - Deliberate Indifference (both 14th and 5th Amendments), Substantive Due Process - Punitive Detention (both 14th and 5th Amendments)
CARES Act, Pub. L. No. 116-136, First Step Act Exhaustion, First Step Act, 18 U.S.C. § 3582(c)(1)(A), § 2241 Habeas, § 2241 Habeas Exhaustion, § 2254 Habeas
Placement in home confinement dependent on: not being convicted on the basis of a violent or sexual offense; not having a "High" PATTERN score (which determines the risk of recidivism); assignment by the warden to RRC (Residential Reentry Center) on the basis of preexisting health issues
Conspiracy to possess with intent to distribute one kilogram or more of heroin; Conspiracy to distribute one kilogram or more of heroin; Wire fraud; Conspiracy to commit wire fraud; Willful failure to file an income tax return
Decision Made But Case Still Pending
Motions Partially Granted
The motion was partially granted because the judge placed conditions on what would allow for incarcerated individuals designated for placement in an RRC to instead be released into home confinement. Specifically, as noted above, the incarcerated person must not be convicted of a violent or sex-related crime and must not have a "High" PATTERN score.
Compassionate Release Exhaustion Holdingsin Federal Case
An individual can move for compassionate release after 30 days have passed from the date the application was submitted to the warden, irrespective of whether the warden has granted or denied the request., Exhaustion is subject to equitable exceptions.
Age (64); Hepatitis C; Medication-Related Immunocompromise (corticosteroids)
Class Action Medically Vulnerable People
Medically vulnerable inmates at high risk of serious illness or death from COVID-19.
COVID-19 Positive or Symptomatic
COVID-19 in Jail Prison or Detention Center
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.
This resource is designed to help lawyers, advocates, researchers, journalists, and others interested in challenging, remedying, or drawing attention to the grave risk that Covid-19 poses to individuals who are detained.