COVID-19 Summary: On April 4, 2020, individuals detained in Miami-Dade County jails filed a class action complaint in the U.S. District Court for the Southern District of Florida, seeking habeas, injunctive, and declaratory relief. The court granted plaintiff’s motion for a TRO and preliminary injunction in part, and the defendants appealed to the Eleventh Circuit. On June 15, the Eleventh Circuit vacated the preliminary injunction. A jury trial was scheduled for March 1, 2021, but the case was voluntarily dismissed on September 29.
On April 4, 2020, individuals detained in the Miami-Dade County jails filed this class action complaint in the U.S. District Court for the Southern District of Florida. The plaintiffs, who alleged they were particularly vulnerable to COVID-19, sued the County and County officials. The plaintiffs, represented by the Advancement Project, Community Justice Project, Civil Rights Corps, and Dream Defenders, sought a writ of habeas corpus and injunctive and declaratory relief under 42 U.S.C. § 1983. They claimed that the defendants violated their Eighth and Fourteenth Amendment rights. Specifically, the plaintiffs alleged that conditions at the Metro West jail endangered their health and safety during the COVID-19 pandemic. They alleged that the defendants failed to provide basic hygiene supplies, health care, testing, or social distancing. The plaintiffs argued that the risk was severe because at least 15 jail employees had tested positive for COVID-19 as of April 4.
On April 5, the plaintiffs filed an emergency motion for a temporary restraining order and preliminary injunction. The plaintiffs asked the court to require defendants to take basic steps to safeguard the health of individuals at the jail who, due to their confinement, experienced an increased risk of infection and death. Plaintiffs also sought immediate release for people who were particularly vulnerable because of age or preexisting medical conditions.
Also on April 5, the plaintiffs filed a motion for class certification. The class would include “all current and future persons detained at Metro West during the course of the COVID-19 pandemic.” Separately, the plaintiffs defined a medically-vulnerable subclass as “all current and future persons held at Metro West over the age of fifty, as well as all current and future persons held at Metro West of any age who experience an underlying medical condition that places them at particular risk of serious illness or death from COVID-19.” The subclass sought a writ of habeas corpus.
The court held a conference on the TRO order on April 6 before Judge Kathleen Williams. On April 7, the court referred the case to Magistrate Judge Edwin Torres for discovery issues.
Also on April 7, Judge Williams issued an order granting in part plaintiff’s emergency motion for a TRO. 2020 WL 1692668. The order required that by April 9, defendants file under seal a list of all medically vulnerable individuals who were detained at Metro West and a notice describing the particular measures they employed to protect these individuals from the risk of COVID-19. Further, the court ordered that defendants communicate sufficient information about COVID-19 and measures taken to reduce risk, implement social distancing measures, ensure that each incarcerated person receives free hygiene products, provide reasonable access to showers and laundry, require jail staff to wear PPE and regularly wash their hands, ensure proper testing for individuals with symptoms, and waive charges for medical care. To address individuals diagnosed with or exposed to COVID-19, the court ordered that defendants provide adequate medical care and quarantine procedures that allow continued access to showers, mental health services, and phone calls with family without placing these individuals in cells used for disciplinary confinement. 2020 WL 1692668.
On April 21, the defendants filed a motion to dismiss for failure to exhaust administrative remedies required by the Prison Litigation Reform Act.
The court granted in part the plaintiff’s motion for preliminary injunction, but denied their request for immediate release on April 29. 457 F.Supp.3d 1287 (Apr. 29, 2020). The preliminary injunction was in effect for a period of 45 days and required the defendants to implement adequate distancing, communication, hygienic supplies, testing, and medical care free of charge for COVID-19 related symptoms. The defendants were also required to provide the court a report of COVID-19 population every three days and a proposal outlining steps to ensure additional social distancing safeguards within 7 days. One of the plaintiffs, Winfred Hill, was released the week before the order and his claims were dismissed as moot.
The same day, the defendants appealed to the U.S. Court of Appeals for the Eleventh Circuit. On May 5, the Eleventh Circuit granted the defendant’s motion for a stay pending appeal, staying the injunction issued by the District Court requiring COVID-19 safety measures. 958 F.3d 1081.
A group of corrections experts and a separate group of Eighth Amendment scholars filed amicus briefs in support of the plaintiffs.
On June 2, the plaintiffs filed a motion for reconsideration of the dismissal of plaintiff Winfred Hill's claims as moot. They argued that the court intended to dismiss all of Hill’s claims, even those on behalf of the class. Therefore, they sought an order clarifying that Hill's claims on behalf of the class were not moot. The defendants did not oppose the motion and the court ordered that the claims of any released plaintiffs on behalf of the class were not moot on June 17. The motion was later denied on July 28.
On June 15, the Eleventh Circuit vacated the preliminary injunction and remanded the case back to the district court. 961 F.3d 1276 (Jun. 15, 2020). The appellate court found that the district court erred in concluding that the plaintiffs had met the deliberate indifference requirement for the preliminary injunction, stating that “[f]ailing to do the ‘impossible’ doesn’t evince indifference, let alone deliberate indifference.”
A jury trial was scheduled for March 1, 2021, but after a few weeks of discovery, the parties filed a notice of voluntary dismissal on September 28, 2020.
Chandler Hart-McGonigle - 11/30/2020
Averyn Lee - 09/16/2020
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