Valenzuela Arias v. Decker (S.D.N.Y.) - PI Grant - Immigration, Release, Pre-Existing Health Conditions
The court granted release to three Petitioners in immigration detention and converted a TRO to a PI to restrain respondents from "arresting Petitioners for immigration detention purposes during the pendency of their immigration proceedings." All Petitioners had pre-existing health conditions, including, among the three of them, breathlessness, chronic pain, PTSD, depression, anxiety, and gynecomastia. The court found that a PI was necessary because these health conditions left Petitioners vulnerable to irreparable harm from COVID-19 if they were to stay in detention in Essex County Jail. The court found the facility’s efforts to contain the spread of the virus insufficient, so continued detention would violate Petitioners' due process rights under the 5th Amendment. The court noted that even if the Petitioners had not met the PI standard, it “would release them on bail pending final resolution of their habeas claims under the Second Circuit’s decision in Mapp v. Reno.”
Preliminary Injunction (PI), Release, Temporary Restraining Order (TRO)
Type of Court
Federal District Court
Location
New York
Type of Case
Group
Case Characteristics
Immigrant Detention, Pre-Existing Health Conditions
Release Granted
Yes
Compassionate Release Case
No
Case Tracking Number
1:20-cv-02802-AT
MORE CASE INFORMATION
Court Name
S.D.N.Y.
Decision
Motion Granted
Place of Incarceration
Local / County Jail
Name of Facility
Essex County Correctional Facility
Legal Authority
Substantive Due Process - Deliberate Indifference (both 14th and 5th Amendments)
Legal Authority
§ 2241 Habeas
Release Conditions
“The court established conditions for release for petitioners (ECF Nos. 20 & 21), and those conditions continue to apply.”
Case Status
Decision Made
Pre-Existing Health Conditions
Anxiety, Depression, Diabetes, High Cholesterol, Other, PTSD, Rib and chest wall injuries that result in breathlessness and chronic pain; Gynecomastia, which can be associated with testicular tumors, liver disease, and hyperthyroidism
COVID-19 in Jail Prison or Detention Center
Yes
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.