Anthony Swain v. Daniel Junior
958 F.3d 1081
| 11th Cir. | 2020Background
- Metro West Detention Center in Miami-Dade experienced COVID-19 cases; seven inmates filed a class action (§ 1983 and § 2241) on April 5, 2020, seeking injunctive relief and release for a medically vulnerable subclass.
- MDCR had implemented multiple CDC-recommended and other mitigation measures (screenings, masks, enhanced cleaning, cohorting/quarantine, staggered bunks), and the district court accepted those measures as true for injunctive-relief purposes.
- The district court issued a TRO and then, after a hearing, a broad preliminary injunction (April 29, 2020) requiring numerous CDC-consistent supplies, testing, quarantine practices, social distancing to the extent possible, reporting, and other operational mandates.
- The Eleventh Circuit granted a stay of that preliminary injunction pending appeal and expedited the appeal, concluding defendants likely to succeed on appeal and that stay factors (irreparable harm, balance of harms, public interest) favored a stay.
- The panel majority faulted the district court for collapsing the objective/subjective deliberate-indifference inquiry, not addressing Monell municipal-liability requirements, and failing to resolve PLRA exhaustion—any of which likely make the injunction erroneous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether injunction was appropriate under the Eighth/Fourteenth deliberate-indifference standard | Metro West conditions (lack of adequate soap/towels, close sleeping quarters, delayed care, inadequate disinfectant) and rising infections show intolerable risk and deliberate indifference | Defendants acted reasonably and implemented many CDC-recommended measures; increased infections and imperfect distancing do not establish deliberate indifference | Court: District likely erred by collapsing objective/subjective elements and by treating inability to fully social distance as deliberate indifference; defendants likely to prevail on merits |
| Whether plaintiffs needed to establish Monell municipal liability at preliminary-injunction stage | Plaintiffs argued Monell was not a prerequisite to injunctive relief at this stage | County argued injunction against a municipality requires a showing of municipal policy/custom causation (Monell) before prospective relief | Court: District likely erred in skipping Monell; plaintiffs must show likelihood of satisfying Monell to obtain injunctive relief against county/official in official capacity |
| Whether PLRA exhaustion should be resolved before granting preliminary relief | Plaintiffs contended exhaustion was an affirmative defense not dispositive at injunction stage | Defendants argued §1997e(a) exhaustion is a threshold requirement and must be resolved (if defenses are "available") before relief | Court: District likely erred by declining to resolve exhaustion; defendants raised the defense and court should have assessed whether defendants were likely to establish failure to exhaust |
| Whether stay factors (irreparable injury, balance of harms, public interest) favored a stay | Plaintiffs argued immediate risk of irreparable harm to inmates outweighs any administrative concerns | Defendants argued injunction usurped prison administration, forced resource diversion, and displaced local officials’ discretion during pandemic | Held: Stay granted—defendants showed irreparable injury from loss of discretion and administrative usurpation; balance of harms and public interest favor stay |
Key Cases Cited
- Nken v. Holder, 556 U.S. 418 (stay factors and standard)
- Hilton v. Braunskill, 481 U.S. 770 (stay factors framework)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard: objective and subjective components)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (municipal liability requires policy or custom causing injury)
- Los Angeles Cty. v. Humphries, 562 U.S. 29 (Monell applies to prospective relief)
- Woodford v. Ngo, 548 U.S. 81 (administrative exhaustion principles)
- Wreal, LLC v. Amazon.com, Inc., 840 F.3d 1244 (preliminary injunction burden and standards in Eleventh Circuit)
- Ross v. Blake, 136 S. Ct. 1850 (availability of administrative remedies under PLRA)
- Jones v. Bock, 549 U.S. 199 (exhaustion as affirmative defense; pleading rules)
- Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (preliminary-injunction burdens track trial burdens)