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Constitutional Rights & the Public’s Health

Laddy Curtis Valentine v. Bryan Collier

Overview

Laddy Curtis Valentine v. Bryan Collier (U.S. Supreme Court, May 14, 2020): The U.S. Supreme Court denied a request to vacate the Fifth Circuit’s stay of a preliminary injunction against a Texas geriatric prison. Inmates argued that the prison violated their 8th Amendment rights by failing to implement measures to adequately protect them from the spread of COVID-19. The district court found they sufficiently alleged deliberate indifference under the 8th Amendment and granted a preliminary injunction requiring the prison to follow extensive cleaning protocols. The Fifth Circuit stayed the injunction, pending appeal. In concurrence, Justice Sotomayor, joined by Justice Ginsberg, found that the inmates did not file any grievance with the prison itself, therefore failing to exhaust administrative remedies as required by the Prison Litigation and Reform Act  of 1995 (PLRA). Justice Sotomayor, however, critiqued the Fifth Circuit’s reasoning on “exhaustion,” with respect to a PLRA exception allowing inmates to bypass this requirement when the administrative grievance procedure is incapable of responding to imminent harm. She  also highlighted “disturbing” allegations brought by the prisoners, including the prison’s failure to apply its own safety protocols. Read the decision here.

View all cases in the Judicial Trends in Public Health – June 15, 2020.

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