Laddy Valentine v. Bryan Collier, 956 F.3d 797

Background

Two inmates at TDCJ’s Wallace Pack Unit (geriatric/high-risk population) filed a class action alleging Eighth Amendment and ADA violations and sought a preliminary injunction to force extensive COVID-19 mitigation measures.
The district court granted a detailed injunction requiring, among other things, alcohol-based hand sanitizer, frequent bleach cleaning (every 30 minutes in common areas), masks for all inmates and staff, testing/quarantine plans, limits on new admissions and transport, signage and education, and suspension of co-pays during the pandemic.
The district court acknowledged many measures overlapped with TDCJ policy and CDC guidance but concluded additional requirements were constitutionally necessary.
TDCJ appealed and moved to stay the injunction pending appeal; the Fifth Circuit granted the stay under Rule 8 and expedited the appeal.
The Fifth Circuit held TDCJ likely to succeed on appeal because (a) Plaintiffs failed to show a constitutionally substantial risk after accounting for TDCJ’s measures and (b) the district court misapplied Farmer by conflating objective risk with subjective deliberate indifference.
The Fifth Circuit also found Plaintiffs likely failed PLRA exhaustion and that the injunction likely violated PLRA’s narrowness/comity constraints and improperly enjoined compliance with state law/policy.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether TDCJ’s COVID measures create an objectively intolerable risk under the Eighth Amendment	Conditions and TDCJ measures are inadequate to protect high-risk inmates from COVID-19	TDCJ adopted evolving CDC-guided policies and protective measures; risk is mitigated	Court: Plaintiffs did not show a substantial risk that rises to Eighth Amendment violation after accounting for TDCJ measures; TDCJ likely to prevail on merits
Whether defendants acted with subjective deliberate indifference (Farmer)	TDCJ’s policies and administration show deliberate indifference or are administered inadequately	TDCJ officials acted pursuant to medical guidance; no evidence they subjectively believed measures were inadequate	Court: District court misapplied Farmer by collapsing objective and subjective prongs; mere disagreement with policy is not deliberate indifference
Whether plaintiffs exhausted administrative remedies under the PLRA before suing	Exhaustion would be impracticable given urgency; grievance process too slow for COVID-19 emergency	Plaintiffs did not file any TDCJ grievance; grievance system is available and can provide some relief	Court: Plaintiffs likely failed mandatory PLRA exhaustion; no special‑circumstances exception applies here; stay warranted
Whether the preliminary injunction complies with PLRA narrowness/comity and Eleventh Amendment/Pennhurst constraints	Broad, specific injunction needed to protect inmates’ health	The injunction is overbroad, micromanages prison operations, and improperly compels adherence to state policy	Court: Injunction likely exceeds PLRA’s requirement to be narrowly drawn and least intrusive and improperly enjoins state prison administration; irreparable state harm supports stay

Key Cases Cited

Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard requires both objective risk and subjective knowledge)
Nken v. Holder, 556 U.S. 418 (stay factors for injunctions pending appeal)
Ross v. Blake, 136 S. Ct. 1850 (availability standard for PLRA exhaustion)
Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (limits on federal courts enjoining states to follow state law)
Booth v. Churner, 532 U.S. 731 (PLRA exhaustion is mandatory; remedies considered "available" if they can grant some relief)
Woodford v. Ngo, 548 U.S. 81 (principles on prison administration and exhaustion-related doctrines)
Jacobson v. Massachusetts, 197 U.S. 11 (deference to public-health measures in emergencies)
Cadena v. El Paso Cty., 946 F.3d 717 (Fifth Circuit discussion of deliberate indifference standard)