Individuals incarcerated at a prison for the elderly and infirm brought a class action challenging, on Eighth Amendment grounds, the sufficiency of preventive measures in place to prevent the spread of COVID-19 at the prison. The district court granted their motion for preliminary injunction, but defendants appealed and moved for a stay of the injunction pending appeal. The Fifth Circuit held that the prison officials were entitled to a stay pending appeal of the preliminary injunction issued by the district court, which had required the officials to immediately implement more drastic preventive measures, in excess of those suggested by CDC guidelines. The Fifth Circuit opined that preliminary injunctive relief was inappropriate under the PLRA because (1) plaintiffs had not exhausted their claims; and (2) the injunction was not narrowly tailored.
Valentine v. Collier, 956 F.3d 797 (5th Cir. 2020)
Elderly, Post-Conviction Detention [jail or prison], Pre-Existing Health Conditions
Release Granted
No
Compassionate Release Case
No
Compassionate Release Specific Characteristics
Has a significant criminal history
Case Tracking Number
20-20207
MORE CASE INFORMATION
Court Name
5th Cir.
Decision
Other
Place of Incarceration
State Prison
Name of Facility
Texas Department of Criminal Justice Wallace Pack Unit
Legal Authority
Eighth Amendment - Deliberate Indifference
Legal Authority
First Step Act Exhaustion, First Step Act, 18 U.S.C. § 3582(c)(1)(A), Prison Litigation Reform Act (PLRA) Exhaustion
Case Status
Decision Made But Case Still Pending
Pre-Existing Health Conditions
Age, High Cholesterol, Hypertension (high blood pressure), Other, Traumatic Brain Injury, Right-side Hemiplegia (muscle weakness/partial paralysis on right side of body)
COVID-19 Positive or Symptomatic
Not discussed
COVID-19 in Jail Prison or Detention Center
Not Discussed
Litigation Database
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.