140 S. Ct. 1598
SCOTUS2020Background
- Pack Unit (Texas) is a dormitory-style geriatric prison housing ~1,200 inmates, over 800 aged 65+; physical layout and population made COVID-19 spread particularly likely.
- An inmate (Leonard Clerkly) developed respiratory symptoms, was hospitalized, and died; District Court found the facility failed to identify, isolate, or treat him before transport.
- District Court heard unrebutted testimony and visited the Pack Unit, finding pervasive noncompliance with the prison’s own COVID protocols (insufficient cleaning, inadequate PPE, janitorial shortages) and concluded those failures showed deliberate indifference under the Eighth Amendment.
- The District Court entered an extensive injunction requiring mitigation measures (cleaning, education, isolation processes, etc.).
- The Fifth Circuit stayed that injunction pending appeal, concluding exhaustion under the PLRA was likely lacking and crediting the prison’s asserted protective measures.
- The Supreme Court denied the inmates’ application to vacate the Fifth Circuit stay; Justice Sotomayor (joined by Justice Ginsburg) filed a separate statement emphasizing the dire facts, noting possible PLRA exhaustion exceptions where grievance systems are unavailable, and underscoring courts’ duty to prevent deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this Court should vacate the Fifth Circuit’s stay of the district-court injunction | Vacate the stay because district court made detailed factual findings showing imminent danger and deliberate indifference requiring immediate relief | Keep the stay because Fifth Circuit reasonably found procedural defects and credited prison mitigation efforts | Application to vacate denied; high standard for undoing a stay not met |
| Whether plaintiffs exhausted PLRA administrative remedies | Grievance process may be unavailable/dead-end in a rapidly spreading pandemic, so exhaustion exception applies | Plaintiffs did not file grievances before suing; PLRA exhaustion requirement bars relief | Fifth Circuit found plaintiffs likely failed to exhaust; Sotomayor noted exception may apply where grievance procedures are unavailable |
| Whether the Pack Unit officials were deliberately indifferent in violation of the Eighth Amendment | Failure to follow own protocols, inadequate cleaning/PPE, and delayed precautions show deliberate indifference to serious medical needs | Officials point to implemented protective measures and argue Eighth Amendment does not require more than their steps | District Court found likelihood of success on deliberate-indifference claim; Fifth Circuit stayed injunction; Supreme Court denied vacatur without resolving merits |
| Whether an appellate court must defer to district-court factfinding on intensely fact-based claims | District court’s live testimony and site visit warrant deference to its factual findings | Appellate panel evaluated the record and relief balance for stay | Sotomayor criticized Fifth Circuit’s failure to fully defer to district-court factfinding, though she did not vacate the stay |
Key Cases Cited
- Western Airlines, Inc. v. Teamsters, 480 U.S. 1301 (1987) (standard for vacating a lower-court stay; high bar for applicants)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference framework)
- Anderson v. Bessemer City, 470 U.S. 564 (1985) (appellate deference to district-court factfindings)
- Ross v. Blake, 136 S. Ct. 1850 (2016) (PLRA requires exhaustion of "available" remedies; procedures that are a "dead end" may be unavailable)
- Valentine v. Collier, 966 F.3d 797 (5th Cir. 2020) (Fifth Circuit stayed district-court injunction pending appeal)