Appeals Court Overturns Ruling On COVID-19 In Jail

Jun 16, 2020

Disputing that officials had shown “deliberate indifference,” a pided federal appeals court Monday overturned a preliminary injunction that sought to force Miami-Dade County to take additional steps to curb COVID-19 at a jail. 

The 2-1 ruling by a panel of the 11th U.S. Circuit Court of Appeals came in a class-action lawsuit filed in April by pretrial detainees at Metro West Detention Center against Miami-Dade County and Daniel Junior, director of corrections and rehabilitation. 

The lawsuit alleged that the plaintiffs’ constitutional rights were being violated, at least in part because the jail did not comply with public health guidelines to prevent an outbreak of COVID-19. Among the allegations was that safe social distancing was not being carried out. 

A U.S. district judge on April 29 issued a preliminary injunction ordering additional steps to prevent spread of the disease, including actions to comply with social distancing. The county appealed and sought a stay of the preliminary injunction, which was granted. 

In overturning the injunction Monday, the appeals-court majority pointed to steps that the county had taken to prevent spread of the disease in the jail and said a key legal test was whether officials had shown deliberate indifference. 

“Whatever deliberate indifference is, the defendants’ conduct here doesn’t show it,” said the 34-page majority opinion, written by Judge Kevin Newsom and joined by Judge W. Keith Watkins. “The district court erred in holding that the defendants acted with a deliberately indifferent mental state, equivalent to ‘subjective recklessness as used in the criminal law.’ We simply cannot conclude that, when faced with a perfect storm of a contagious virus and the space constraints inherent in a correctional facility, the defendants here acted unreasonably by ‘doing their best.’ ” 

Judge Beverly Martin wrote a 20-page dissent that the county did not take adequate steps to reduce overcrowding in the jail and to ensure social distancing.

“The COVID-19 pandemic is a global health crisis that has taken the lives of thousands and strained every level of our society and government,” Martin wrote. “But crises do not lower the constitutional limits on the conditions in which people may be confined against their will. People held in prisons and detention centers are among the most vulnerable to the ravages of this devastating illness.”