Edward Banks v. Quincy Booth, 3 F.4th 445

March 2020: D.C. mayor declared a COVID-19 public-health emergency; D.C. Department of Corrections implemented protective policies.
March 30, 2020: Pretrial and postconviction inmates filed a class action (§ 1983 and § 2241 habeas claims) challenging jail conditions and sought injunctive relief.
The district court appointed independent amici to inspect facilities, issued a TRO on April 19, 2020 based on amici’s findings, and later ordered further review.
June 18, 2020: The district court entered a preliminary injunction requiring steps (e.g., 24-hour medical response, COVID cleaning contracts, nonpunitive quarantine, confidential legal calls).
D.C. Corrections moved to vacate the injunction for changed circumstances and appealed; the district court denied vacatur. On appeal, Corrections argued the PLRA’s 90‑day limit had caused the preliminary injunction to expire and thus the appeal was moot. The D.C. Circuit agreed and dismissed the appeals, remanding for further proceedings as needed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the PLRA 90‑day automatic expiration for preliminary injunctive relief applies to this suit	The joinder of a habeas claim and the nature of the petition place the case outside § 3626(a)(2)	The suit is a civil action "with respect to prison conditions," so § 3626(a)(2) governs and the preliminary injunction expired after 90 days	PLRA applies; the preliminary injunction expired on its 90th day and the appeals are moot
Whether joining a habeas claim prevents § 3626(a)(2) from applying	Joinder of a habeas claim changes the action’s character and exempts it from the PLRA limit	Joinder cannot be used to evade the PLRA; a habeas claim attached to a conditions suit does not defeat the statute’s plain meaning	Joinder does not defeat the PLRA; Congress’ text controls and pleading cannot evade the statute
Whether the district court erred in refusing to vacate the injunction for changed circumstances	The injunction should remain in place to protect inmates	Changed circumstances justified vacatur (and in any event the injunction had run under PLRA)	Court did not reach the merits because the injunction had expired; appeal dismissed as moot and case remanded for any remaining claims

Hope v. Warden York Cty. Prison, 972 F.3d 310 (3d Cir. 2020) (assumed PLRA applies to similar prison‑conditions preliminary relief)
Swain v. Junior, 961 F.3d 1276 (11th Cir. 2020) (assumed PLRA’s 90‑day rule governs analogous injunctions)
Valentine v. Collier, 956 F.3d 797 (5th Cir. 2020) (applied PLRA limits to preliminary injunctive relief in prison‑conditions suits)
Am. Bar Ass’n v. FTC, 430 F.3d 457 (D.C. Cir. 2005) (statutory interpretation principle: Congress says what it means)
In re Smith, 114 F.3d 1247 (D.C. Cir. 1997) (courts should not permit evasion of PLRA by recharacterizing claims)
Blair‑Bey v. Quick, 151 F.3d 1036 (D.C. Cir. 1998) (similar limitation on pleading to avoid PLRA requirements)
Whitman v. Am. Trucking Ass’ns, 531 U.S. 457 (2001) (textualist canon: courts respect clear statutory language)