Part one: complete case summaries in alphabetical order.

Position:Case overview
 
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  1. ADMINISTRATIVE SEGREGATION: Pretrial Detainee, Due Process, Placement in Segregation, Restraints

  2. CLASSIFICATION & SEPARATION: Pretrial Detainees, Segregation

  3. PRETRIAL DETENTION: Punishment, Restraints, Segregation, Due Process

    Allah v. Milling, 982 F.Supp.2d 172 (D.Conn. 2013). A pretrial detainee brought an action against prison officials, asserting claims for violation of the Eighth Amendment and his due process rights under the Fourteenth Amendment based on his placement in an administrative segregation program. The officials moved for summary judgment on the due process claims. The district court denied the motion, finding that summary judgment was precluded by several fact issues. The court held that a genuine issue of material fact existed as to whether the decision by prison officials to place the pretrial detainee, who had previously been in an administrative segregation program before being discharged from the correctional facility, in administrative segregation immediately upon his readmission for a subsequent offense, was for a punitive purpose or was based on a legitimate non-punitive purpose. The court found that a fact issue existed as to whether the restrictions imposed upon the detainee during his confinement in administrative segregation, including handcuffs and leg shackles, constituted punishment. (Gamer Correctional Institution, Connecticut)

  4. CLASSIFICATION & SEPARATION: Cell Assignment, Failure to Protect, Separation

  5. FAILURE TO PROTECT: Prisoner on Prisoner Assault, Medical Care

  6. MEDICAL CARE: Failure to Provide Care, Inadequate Care

    Alsobrook v. Alvarado, 986 F.Supp.2d 1312 (S.D.Fla. 2013). A state prisoner who was seriously injured in a fight with his cellmate brought a [section] 1983 action against a warden, corrections officers, prison nurse, the prison's healthcare provider, and the Secretary of the Florida Department of Corrections. The defendants moved to dismiss. The district court granted the motions in part and denied in part. The court held that the prisoner sufficiently alleged that a corrections officer was deliberately indifferent to a risk of serious harm posed by the cellmate, in violation of the Eighth Amendment, where: (1) the prisoner alleged that his cellmate told the officer that he would become violent if the prisoner was not removed from the cell; (2) the prisoner requested to be separated from his cellmate; (3) the officer did nothing in response to this information; and (4) that a fight ensued, which resulted in serious injuries to the prisoner.

    The court held that the prisoner sufficiently alleged that the treatment he received from a prison nurse after he was brought to the infirmary following a fight with his cellmate was so grossly inadequate that it amounted to no treatment at all, and thus he stated a [section] 1983 claim that the nurse was deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The prisoner alleged that he was brought to the infirmary with open wounds, swelling on his head and face, and covered with blood, that he vomited while awaiting treatment and, after being "treated," he left the infirmary with open wounds, swelling on his head and face, covered with blood, and with four ibuprofen in his pocket. (South Florida Reception Center, Florida)

  7. FREE SPEACH, EXPRESSION, ASSOC.: Marriage

  8. STANDARDS: State Statute

    Amos v. Higgins, 996 F.Supp.2d 810 (W.D.Mo. 2014). Fiancees of prisoners brought an action against a county recorder of deeds, in her official capacity, asserting that a state law's requirement that a marriage license applicant must sign the application in the presence of a recorder was unconstitutional, as applied in instances when one or both applicants could not appear in person, or when an applicant was incarcerated. The fiancees moved for a preliminary injunction prohibiting the recorder from requiring prisoners to execute or sign their marriage license applications in her presence. The district court granted the motion. The court held that the Missouri statute requiring both applicants to execute and sign a marriage license in presence of the issuing recorder was unconstitutional as applied, and an issuance of a permanent injunction was warranted. The court noted that the "in presence" statutory requirement significantly interfered with the fiancees' exercise of their fundamental right to marry, and it was not closely tailored to solely effectuate a sufficiently important state interest, given that the identity of incarcerated marriage license applicants could be verified through other means without requiring them to sign a marriage license application in the recorder's physical presence. (Moniteau County Recorder of Deeds, Tipton Correctional Center, Missouri)

  9. CONDITIONS OF CONFINEMENT: Temperature, ADA- Americans with Disabilities Act, Medical Care

  10. FACILITIES: Temperature, ADA- Americans with Disabilities Act, General Conditions, Ventilation

  11. MEDICAL CARE: ADA- Americans with Disabilities Act, Deliberate Indifference

    Ball v. LeBlanc, 988 F.Supp.2d 639 (M.D.La. 2013). State death row inmates brought a [section] 1983 action against a state department of corrections and state officials, seeking declaratory and injunctive relief based on allegations of violations of the Eighth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act. The district court granted declaratory and injunctive relief in part and denied in part. The court held that the temperature and humidity of cells presented a substantial risk of harm to death row inmates, as required for their claims against the prison and officials, alleging the conditions of confinement violated the Eighth Amendment. The court noted that: (1) the inmates were regularly subjected to temperatures above 90.5 degrees and heat indices above 100 degrees; (2) the heat index inside death row tiers was often higher than that outside the facility; (3) inmates were subjected to consecutive days with heat indices above 100 degrees; (4) inmates were at risk of heat-related illnesses including heat stroke and worsening of their underlying conditions, which included diabetes, hypertension, and uncontrolled blood pressure; and (5) two inmates were over age 55, increasing the risk for them.

    The court found that prison officials had knowledge that the heat and humidity in death row tiers placed inmates at a substantial risk of harm, as required to find the officials were deliberately indifferent to the serious medical needs for the purpose of the inmates' Eighth Amendment claims. The inmates had submitted multiple administrative complaints regarding the heat, and officials responded that they knew it was "extremely hot." According to the court, prison officials disregarded the substantial risk of serious harm to death row inmates regarding heat and humidity in cells, as required to find that the officials were deliberately indifferent to the serious medical needs for the purpose of the inmates' Eighth Amendment claims, where the officials did not take any actions to reduce the heat conditions despite knowledge of the conditions.

    The court found that there was no evidence that death row inmates were limited in any major life activities due to their medical conditions, including hypertension, obesity, and depression, as required for their claims against the prison and officials, alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. (Louisiana State Penitentiary)

  12. FAILURE TO PROTECT: Juveniles, Suicide Attempt

  13. JUVENILES: Use of Force, Medical Care, Suicide Attempt, Due Process

  14. MEDICAL CARE: Juvenile, Mental Health, Delay in Care

  15. MENTAL PROBLEMS (PRISONER): Juvenile, Restraints, Failure to Provide Care, Deliberate Indifference

  16. PRETRIAL DETENTION: Juveniles, Medical Care, Mental Health, Restraints, Use of Force, Due Process

  17. TRANSFERS: Denial

  18. USE OF FORCE: Restraining Chair, Excessive Force

    Blackmon v. Sutton, 734 F.3d 1237 (10th Cir. 2013). A former juvenile pretrial detainee brought a [section] 1983 action against various members of a juvenile detention center's staff, alleging they violated the Fourteenth Amendment rights guaranteed to him as a pretrial detainee. The district court denied the defendants' motion for summary judgment based on qualified immunity. The defendants appealed. The appeals court affirmed in part, and reversed in part. The court held that the eleven-year-old pretrial detainee's right to be free from punishment altogether was clearly established at the time the staff allegedly used a chair bearing wrist, waist, chest, and ankle restraints to punish detainee, for the purposes of the juvenile detention center's staffs qualified immunity defense. According to the court, the senior correctional officer approved a decision by one of his subordinates, a fully grown man, to sit on the chest of the eleven-year- old without any penological purpose. The court found that the detainee's Fourteenth Amendment due process rights were violated when employees allegedly failed to provide the eleven-year-old detainee with any meaningful mental health care despite his obvious need for it. The court noted that prison officials who assumed a "gate keeping" authority over the prisoner's access to medical professionals were deliberately indifferent to the detainee's medical needs when they denied or delayed access to medical care. But the court also held that the detainee's alleged right to be placed in a particular facility of his choice while awaiting trial was not clearly established at the time the director failed to transfer detainee to a nearby shelter, for purposes of the juvenile detention center director's qualified immunity defense.. The court stated: "Weeks before eleven-year-old, 4'11," 96-pound Brandon Blackmon arrived at the juvenile detention center in Sedgwick, Kansas, officials there made a new purchase: the Pro- Straint Restraining Chair...

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