177 F. Supp. 3d 474
D.D.C.2016Background
- Jeremy Pinson, a federal prisoner proceeding pro se, sued DOJ and BOP officials alleging FOIA/Privacy Act violations and Bivens retaliation claims against Director Charles Samuels and other BOP staff for adverse conditions at ADX Florence.
- Pinson alleged he was placed in the Special Housing Unit (SHU/solitary) on August 10, 2015 as retaliation for litigation and media contacts, suffered restricted mental-health treatment, limited law-library and mail access, and other harassment.
- Defendants maintain the SHU placement was for safety and institutional order following disruptive conduct; they deny Samuels ordered retaliation and produce library/mail usage records and denials by BOP staff.
- Pinson sought a preliminary injunction restoring his pre-August 10, 2015 status: placement in STAGES housing, full mental-health access, law-library access, and access to court filings.
- Between briefing and decision, Pinson was transferred from ADX Florence to a Pennsylvania facility; defendants argued his transfer moots the injunctive relief claims.
- The Court denied the preliminary injunction (and found related motions moot) because Pinson’s transfer rendered the injunctive relief challenge to ADX Florence conditions moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether preliminary injunctive relief is warranted to address alleged retaliatory conditions at ADX Florence | Pinson argued he faced ongoing severe retaliation at ADX Florence (SHU placement, reduced mental-health care, restricted mail/library) requiring immediate relief | Defendants argued the SHU placement was for legitimate safety reasons, denied retaliatory intent, and produced records showing access to mail/library; later noted Pinson was transferred | Denied as moot: transfer from ADX Florence removed the live controversy over those conditions, so injunction not warranted |
| Whether ancillary motions (evidentiary hearing, motion to supplement, Rule 11 sanctions) remain viable | Pinson sought an evidentiary hearing and to supplement his filings; sought sanctions against defendants | Defendants opposed and cited mootness after transfer | Denied/declined as moot or unnecessary given denial of preliminary injunction; Rule 11 sanctions inappropriate in light of ruling |
Key Cases Cited
- Mazurek v. Armstrong, 520 U.S. 968 (U.S. 1997) (preliminary injunction is an extraordinary remedy requiring clear showing)
- Winter v. Natural Res. Def. Council, 555 U.S. 7 (U.S. 2008) (standards for preliminary injunction: likelihood of success, irreparable harm, balance of equities, public interest)
- Abdullahi v. Obama, 753 F.3d 193 (D.C. Cir. 2014) (discussing preliminary injunction standards in D.C. Circuit)
- Davis v. Pension Benefit Guar. Corp., 571 F.3d 1288 (D.C. Cir. 2009) (sliding-scale approach among injunction factors)
- Chaplaincy of Full Gospel Churches v. England, 454 F.3d 290 (D.C. Cir. 2006) (failure to show irreparable harm bars injunction)
- Scott v. District of Columbia, 139 F.3d 940 (D.C. Cir. 1998) (prisoner transfer generally moots equitable claims about prior facility conditions)
- Brown v. F.B.I., 793 F. Supp. 2d 368 (D.D.C. 2011) (prisoner transfer rendered preliminary injunction challenge to SHU placement moot)