Topic
Every decision we've filed under Civil Rights - PLRA / Prisoner.
The Second Circuit vacated the dismissal of a pretrial detainee's Fourteenth Amendment claims regarding unsanitary conditions and segregation without a hearing. The court also reversed summary judgment on a failure-to-protect claim, finding a factual dispute over whether the plaintiff exhausted administrative remedies under the PLRA.
The Second Circuit vacated a default judgment against a corrections officer, ruling that the district court abused its discretion by awarding damages while dismissing identical claims against co-defendants for failure to exhaust administrative remedies. Applying the prohibition on inconsistent judgments, the court held that a plaintiff cannot prevail against a defaulting defendant when the same legal bar precludes the claims against litigating co-defendants.
The D.C. Circuit affirmed the dismissal of a civil rights complaint because the plaintiff failed to provide a short, plain statement of the claim required by Federal Rule of Civil Procedure 8(a). The court further held that the district court correctly denied leave to amend the complaint, as the proposed changes would not have cured the original pleading deficiencies.
The Second Circuit held that periodic reviews of a Connecticut prisoner's administrative segregation status satisfied due process even while he was incarcerated in Virginia. However, the court found a genuine dispute of material fact regarding whether Virginia Department of Corrections administrative remedies were available to the plaintiff, rendering summary judgment on his First, Sixth, and Eighth Amendment claims inappropriate.
The Ninth Circuit affirmed the denial of preliminary injunctive relief to death row inmate Thomas Creech regarding his scheduled lethal injection. The court held that Creech failed to demonstrate a likelihood of success on his Due Process and Eighth Amendment claims because his arguments about drug provenance were speculative and he offered no viable alternative execution method.