Medically vulnerable individuals in federal criminal custody at Elkton filed a putative class action seeking release, transfer, and other relief due to the COVID-19 pandemic. The district court found the individuals were likely to succeed on the merits of their Eighth Amendment deliberate indifference claims and entered a preliminary injunction ordering respondents to identify vulnerable class members and evaluate them for transfer or release. However, on appeal, the Sixth Circuit vacated the preliminary injunction on the grounds that the prison's mitigating efforts rendered the individuals unlikely to succeed on the merits of their Eighth Amendment claims.
Wilson v. Williams, No. 4:20-CV-00794 (N.D. Ohio Apr. 22, 2020)
DETAILS
Decision
Date
4/22/2020
Practice Area
Criminal (Federal Charges)
Relief Requested
Preliminary Injunction (PI), Release, Transfer
Type of Court
Federal District Court
Location
Ohio
Type of Case
Class Action
Case Characteristics
Elderly, Post-Conviction Detention [jail or prison], Pre-Existing Health Conditions
Through any means, including but not limited to compassionate release, parole or community supervision, transfer furlough, or non-transfer furlough
Case Status
Reversed
Improved Conditions Ordered
"Any subclass members transferred out of Elkton may not be returned to the facility until the threat of the virus is abated or until a vaccine is available and Elkton obtains sufficient vaccine supplies to vaccinate its population, whichever occurs first."
Motions Partially Granted
Motion to certify class granted, but "the Court orders the Respondents to identify, within one day all members of the subclass as defined in this Order." Motion for preliminary injunction granted. Petition for writ of habeas corpus granted.
"[A]ll current and future persons incarcerated at Elkton over the age of 50, as well as all current and future persons incarcerated at Elkton of any age who experience: chronic lung disease or moderate to severe asthma; serious heart conditions; conditions that can cause a person to be immunocompromised, including cancer treatment, smoking, bone marrow or organ transplantation, immune deficiencies, poorly controlled HIV or AIDS or prolonged use of corticosteroids and other immune weakening medications; severe obesity (defined as a body mass index of 40 or higher); diabetes; chronic kidney disease or undergoing dialysis; or liver disease."
COVID-19 Positive or Symptomatic
Yes
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.