Craig Wilson v. Mark Williams
961 F.3d 829
6th Cir.2020Background
- Petitioners (four Elkton inmates) filed a 28 U.S.C. § 2241 habeas petition seeking release for a medically‑vulnerable subclass of Elkton inmates during the COVID‑19 outbreak; district court certified a subclass (inmates 65+ and those with high‑risk conditions) and entered a preliminary injunction directing expedited eligibility reviews and transfers/out‑of‑Elkton removals.
- Elkton FCI is a low‑security, dormitory‑style complex (≈2,500 total capacity across main and satellite facilities) where inmates sleep and live in close proximity; CDC social‑distancing measures are impracticable in that layout.
- As of April 22, 2020 the record showed widespread infection at Elkton (59 inmates and 46 staff positive; six inmate deaths), limited testing capacity, and BOP countermeasures implemented in a six‑phase plan (screening, quarantines, restricted movement, cleaning, PPE distribution).
- Petitioners argued no set of in‑prison conditions could protect the medically vulnerable and therefore sought release; BOP argued it had reasonably responded, §2241 did not permit the transfers the district court ordered, and the PLRA did not apply to habeas.
- The Sixth Circuit held §2241 jurisdiction was proper for claims seeking release but concluded petitioners were unlikely to succeed on the Eighth Amendment deliberate‑indifference claim because the BOP had taken reasonable, evolving measures; the court vacated the preliminary injunction.
- Chief Judge Cole concurred in part and dissented in part: she would have upheld the preliminary injunction, emphasizing (per her view) the BOP’s failure to enable social distancing, inadequate testing/supplies, and insufficient use of home‑confinement authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction: whether §2241 is the proper vehicle | Petitioners: their claim that only release will remedy the constitutional injury means they challenge the fact/extent of confinement and may proceed under §2241 | BOP: this is a conditions‑of‑confinement claim (subject to PLRA) and not properly before §2241 | Held: §2241 jurisdiction is proper for subclass seeking release; PLRA inapplicable to habeas, but §2241 limits the forms of relief available (district court exceeded scope by ordering transfers) |
| Eighth Amendment (deliberate indifference) — objective prong | Petitioners: COVID‑19 plus dormitory housing creates a substantial risk of serious harm to medically vulnerable inmates | BOP: agrees risk is serious but contends it implemented appropriate mitigation steps | Held: Objective prong satisfied (substantial risk shown) |
| Eighth Amendment (deliberate indifference) — subjective prong | Petitioners: BOP measures were ineffective, and failing to use home confinement/transfers shows deliberate indifference | BOP: implemented a multi‑phase, evolving response (screening, isolation, PPE, cleaning, limited movement, expanding testing) and constraints/limits exist on BOP release authority | Held: Petitioners unlikely to prove deliberate indifference; BOP’s response was reasonable as of the record date |
| Preliminary injunction scope and balancing | Petitioners: immediate relief (release/evaluation) required to avoid irreparable harm; district court order was narrowly tailored to evaluate and effectuate release where appropriate | BOP: injunction imposes harms to government operations and public safety, and the district court failed to weigh harms/public interest properly | Held: Because petitioners lacked a likelihood of success, the preliminary injunction was an abuse of discretion and was vacated; court also noted district court inadequately addressed harms and relief scope under §2241 |
Key Cases Cited
- Helling v. McKinney, 509 U.S. 25 (1993) (Eighth Amendment requires prison officials to protect inmates from known, substantial risks to health).
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference test: objective risk and subjective knowledge/disregard; reasonable responses can defeat liability).
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas corpus is the proper vehicle to challenge the fact or duration of confinement).
- Martin v. Overton, 391 F.3d 710 (6th Cir. 2004) (distinguishes conditions‑of‑confinement claims seeking transfer/remedies from habeas challenges to custody).
- Jalili v. Matesanz, 925 F.2d 889 (6th Cir. 1991) (limits on habeas/§2255 relief when challenge concerns execution of sentence and placement).
- Hope v. Pelzer, 536 U.S. 730 (2002) (courts may infer officials’ subjective awareness where risk is obvious).
- Richmond v. Huq, 885 F.3d 928 (6th Cir. 2018) (deliberate indifference where medical care was repeatedly withheld or protocols ignored).
- Darrah v. Krisher, 865 F.3d 361 (6th Cir. 2017) (continued use of an ineffective treatment can constitute no treatment and show deliberate indifference).
- Phillips v. Roane County, 534 F.3d 531 (6th Cir. 2008) (failure to follow medical protocols and obtain needed evaluation supported deliberate‑indifference claim).
- Rouster v. County of Saginaw, 749 F.3d 437 (6th Cir. 2014) (reasonable, well‑intended responses to health risks can defeat deliberate‑indifference claims).
- Swain v. Junior, 958 F.3d 1081 (11th Cir. 2020) (prison’s extensive mitigation measures weighed against finding deliberate indifference in COVID context).
- Valentine v. Collier, 956 F.3d 797 (5th Cir. 2020) (warning against collapsing objective and subjective prongs; consider protective measures when assessing deliberate indifference).