United States v. Williams Jr, 2:20-cr-00028

Defendant Laron Karl Williams, Jr. moved for an order requiring immediate COVID-19 testing if he is detained at the Nevada Southern Detention Center (NSDC).
Williams had been transferred from New Mexico custody and claimed uncertainty about prior facility and NSDC protocols; he sought court-ordered testing as a preventive measure.
He argued the Court has inherent authority to order testing and that testing is necessary to protect his Sixth Amendment right to assistance of counsel and to prepare his defense.
The Court acknowledged COVID-19’s serious risks in detention settings but explained decisions about prisoner care and internal policies ordinarily rest with corrections officials.
The Court found NSDC was taking reasonable precautions and determined it lacked authority to order testing; it also found Williams’ request speculative and that testing would not restore in-person counsel visits.
The Court denied Williams’ motion for immediate COVID-19 testing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has inherent authority to order COVID-19 testing at a detention facility	Defer to corrections officials; internal prison management falls within their expertise	Court should exercise inherent authority to order testing for detainee protection	Denied — court lacks inherent authority to micromanage detention facility operations
Whether failure to test impairs Sixth Amendment right to counsel	Court/prison procedures can accommodate counsel without court-ordered testing	Testing is necessary so defendant can have meaningful, in-person assistance of counsel and prepare a complete defense	Denied — speculative and testing would not guarantee in-person visits; claim unpersuasive
Whether immediate testing is necessary to prevent COVID-19 spread in NSDC	Corrections officials are best positioned to adopt and execute infection-control measures	Immediate testing of detained defendant is crucial to stemming spread and protecting health	Denied — decisions about testing and containment are for corrections officials; NSDC was already taking recommended precautions
Whether defendant presented specific facts showing imminent risk meriting relief	Emphasize need for particularized risk showing rather than generalized speculation	Relied on transfer history and uncertainty about prior facility and protocols to show risk	Denied — court found only generalized speculation, no particularized risk shown

Bell v. Wolfish, 441 U.S. 520 (1979) (courts should defer to corrections officials on internal policies regarding prisoner discipline, care, and security)