453 F.Supp.3d 1103
N.D. Ill.2020Background
- Plaintiffs are ten named IDOC inmates (many convicted of serious violent felonies) who filed two actions—one Section 1983 class action (Money v. Pritzker) and one habeas petition (Money v. Jeffreys)—seeking expedited medical furloughs/home detention for high‑risk inmates during COVID‑19.
- IDOC houses ~37,000 people across 28 facilities; COVID‑19 had produced confirmed infections (notably a Stateville outbreak) and at least one inmate death at the time of briefing.
- Plaintiffs proposed six subclasses (Subclass 1 ≈12,000 medically vulnerable inmates; Subclass 2 ≈4,800 aged 55+) and asked for immediate transfers or a court‑supervised expedited process to effectuate transfers.
- Illinois defendants (Governor, IDOC Director) had implemented multiple COVID responses (executive orders, suspended admissions, expanded furlough discretion, population‑management task force, commutations/releases, quarantine and PPE protocols) and had already reduced population and released inmates via existing mechanisms.
- Court denied the requested TRO/preliminary injunction and expedited habeas relief: held PLRA bars single‑judge prisoner‑release orders of the kind sought, plaintiffs lacked likelihood of success on Eighth Amendment and ADA claims, class treatment and habeas exhaustion problems counseled against relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the PLRA permits a single federal judge to order a court‑managed process or transfers that would reduce prison population | Money: relief is a court‑ordered process (not a mass release) to identify/evaluate eligible furloughs; not a "prisoner release order" under PLRA | Pritzker: any order whose purpose/effect reduces prison population falls within PLRA §3626 and thus requires prior less‑intrusive orders and a three‑judge court for release orders | Held: The requested process would have the purpose/effect of reducing population and falls within PLRA; single judge cannot grant it now. |
| Whether Plaintiffs are likely to succeed on Eighth Amendment (deliberate indifference) claim | Money: congregate prison conditions make social distancing impossible and create an excessive risk of harm; state response is insufficient/too slow | Pritzker: IDOC has taken many constitutionally adequate, evolving measures; individualized release decisions are in place; not deliberately indifferent | Held: No reasonable likelihood of success; defendants are responding and have not exhibited the requisite deliberate indifference. |
| Whether class (and subclasses) certification is appropriate for injunctive relief | Money: common conditions and shared vulnerability justify class treatment and injunctive relief for subclasses | Pritzker: suitability for furlough/release requires individualized assessments (crime, risk, home site, medical status) and thus is ill‑suited for classwide relief | Held: Class treatment inappropriate here—release determinations are inmate‑specific and not apt to drive resolution on a classwide basis. |
| Whether habeas petition can proceed without exhausting state remedies | Money (habeas): emergency justifies federal habeas; state courts (esp. Cook County) were effectively unavailable | Jeffreys/Pritzker: petitioners failed to exhaust available state remedies; state courts in petitioners' jurisdictions were available | Held: Habeas relief denied for failure to exhaust; exhaustion not excused by claimed unavailability. |
Key Cases Cited
- Mazurek v. Armstrong, 520 U.S. 968 (1997) (preliminary injunctive relief is an extraordinary remedy and movant bears heavy burden)
- Winter v. Natural Res. Def. Council, 555 U.S. 7 (2008) (public consequences and balancing of harms central to injunction analysis)
- Turnell v. CentiMark Corp., 796 F.3d 656 (7th Cir. 2015) (two‑step framework for preliminary injunctions; threshold showing then balancing)
- Brown v. Plata, 563 U.S. 493 (2011) (Supreme Court upheld a large‑scale prisoner release remedy after exhaustive record and three‑judge process under PLRA)
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (distinguishing habeas from §1983; habeas traditionally for relief affecting fact or duration of confinement)
- Ziglar v. Abbasi, 137 S. Ct. 1843 (2017) (Supreme Court left open whether habeas can challenge conditions of confinement)
- Turner v. Safley, 482 U.S. 78 (1987) (courts should give deference to prison administrators on management decisions)
- Rosario v. Brown, 670 F.3d 816 (7th Cir. 2012) (deliberate indifference requires conduct approaching total unconcern for prisoner welfare)