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Case Name Martinez v. Donahue IM-GA-0016
Docket / Court 7:20-cv-00062 ( M.D. Ga. )
State/Territory Georgia
Case Type(s) Immigration and/or the Border
Special Collection COVID-19 (novel coronavirus)
Attorney Organization Southern Poverty Law Center
Case Summary
COVID-19 Summary: This is a habeas action brought by immigration detainees in Georgia with underlying medical conditions that made them particularly vulnerable to COVID-19. The detainees alleged that their continued detention was unconstitutional and requested release. The court denied a TRO on ... read more >
COVID-19 Summary: This is a habeas action brought by immigration detainees in Georgia with underlying medical conditions that made them particularly vulnerable to COVID-19. The detainees alleged that their continued detention was unconstitutional and requested release. The court denied a TRO on April 10, and denied a preliminary injunction on June 3. The plaintiffs voluntarily dismissed the action on August 17, 2020.


On April 7, 2020 ICE detainees in Georgia detention centers filed this action in the U.S. District Court for the Middle District of Georgia. Represented by the Southern Poverty Law Center and Asian American Advancing Justice - Atlanta, the plaintiffs sued Immigration and Customs Enforcement (ICE), the Stewart Detention Center, the Irwin County Detention Center, and the Atlanta ICE Field Office. Suing under the federal habeas statute 28 U.S.C. § 2241 for violations of the Fifth Amendment, the detainees alleged that the current conditions in the detention centers were unconstitutional, as they facilitated the spread of COVID-19 and that ICE was not doing enough to prevent it, including: lack of social distancing, poor water quality, lack of disinfectant materials and soap, unsanitary communal areas. They sought the release of the detainees, in light of these unconstitutional conditions of confinement. The case was assigned to Judge Clay D. Land and Magistrate Judge Stephen Hyles.

On April 8, the plaintiffs filed a motion for temporary restraining order, requesting the release of the plaintiffs. The defendants filed a motion in opposition on April 9, stating that they had taken affirmative steps to combat the spread of COVID-19 in ICE facilities including increased screening and sanitization practices, encouraging social distancing, and a focus on medical care.

The court denied the motion for TRO on April 10, finding that the appropriate relief for unconstitutional conditions was not release but discontinuance of any improper practices causing violations of the Constitution. Because the plaintiffs only sought release, Judge Land held that the court had no jurisdiction to decide a habeas claim based upon allegedly unconstitutional conditions of confinement and that release was not an appropriate remedy for the constitutional violations. 2020 WL 1847158

The plaintiffs filed an amended petition for writ of habeas corpus on April 24 and a motion for preliminary injunction on April 30, seeking release or in the alternative, that the court require ICE to follow CDC guidance and take measures to protect detainees from COVID-19. The defendants filed an opposition on May 6. The plaintiffs filed another amended petition on May 18.

Judge Land denied the motion for preliminary injunction on June 3, finding that the plaintiffs had not proved that they were being subjected to unconstitutional conditions of confinement that could only be remedied through release, which meant the court did not have jurisdiction to enter habeas relief. Similarly, because the plaintiffs had not proved unconstitutional conditions, they were not entitled to any other injunctive or declaratory relief they sought, either. 2020 WL 2988307.

On July 6, the defendants filed a motion to dismiss the petition for habeas relief and to stay discovery. That same day, the plaintiffs filed a motion for reconsideration of the June 3 order, citing that the new spread of COVID-19 in the detention facility constituted newly discovered evidence that merited reconsideration. The defendants filed a response to the motion for reconsideration on July 21.

Judge Land denied the motion for reconsideration on July 23, stating that the evidence of the spread of COVID-19 in the center did not change the Court's previous findings and conclusion in a material way.

On August 17, the plaintiffs voluntarily dismissed the case and it appears closed now.

Caitlin Kierum - 10/26/2020


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Due Process: Substantive Due Process
Content of Injunction
Preliminary relief denied
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Conditions of confinement
Housing
Totality of conditions
Immigration/Border
Detention - conditions
Medical/Mental Health
COVID-19 Mitigation Denied
COVID-19 Mitigation Requested
COVID-19 Release Denied
COVID-19 Release Requested
Plaintiff Type
Private Plaintiff
Special Case Type
Habeas
Causes of Action Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255
Defendant(s) Atlanta ICE Field Office
Immigration and Customs Enforcement
Irwin County Detention Center
Stewart Detention Center
Plaintiff Description Detainees in ICE detention facilities in Georgia
Indexed Lawyer Organizations Southern Poverty Law Center
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party None Yet / None
Public Int. Lawyer Yes
Nature of Relief None yet
Source of Relief None yet
Filed 04/07/2020
Case Closing Year 2020
Case Ongoing No
Case Listing IM-GA-0014 : Thompson v. Tsoukaris (N.D. Ga.)
Additional Resources
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Docket(s)
7:20-cv-00062 (M.D. Ga.)
IM-GA-0016-9000.pdf | Detail
Date: 08/17/2020
Source: PACER [Public Access to Court Electronic Records]
General Documents
Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2241 and Complaint for Declaratory and Injunctive Relief [ECF# 1]
IM-GA-0016-0001.pdf | Detail
Date: 04/07/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum of Law in Support of Motion for Temporary Restraining Order and Emergency Writ of Habeas Corpus [ECF# 5-1]
IM-GA-0016-0003.pdf | Detail
Date: 04/08/2020
Source: PACER [Public Access to Court Electronic Records]
Supplemental Memorandum of Law in Support of Motion for Temporary Restraining Order and Emergency Writ of Habeas Corpus [ECF# 9]
IM-GA-0016-0004.pdf | Detail
Date: 04/08/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Opposition to Petitioners' Motion for a Temporary Restraining Order [ECF# 12]
IM-GA-0016-0002.pdf | Detail
Date: 04/09/2020
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 14] (2020 WL 1847158) (M.D. Ga.)
IM-GA-0016-0005.pdf | WESTLAW | Detail
Date: 04/10/2020
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 94] (M.D. Ga.)
IM-GA-0016-0006.pdf | Detail
Date: 06/03/2020
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 109] (M.D. Ga.)
IM-GA-0016-0007.pdf | Detail
Date: 07/23/2020
Source: PACER [Public Access to Court Electronic Records]
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Judges Hyles, M. Stephen Court not on record [Magistrate] show/hide docs
IM-GA-0016-9000
Land, Clay D. (M.D. Ga.) show/hide docs
IM-GA-0016-0005 | IM-GA-0016-0006 | IM-GA-0016-0007 | IM-GA-0016-9000
Plaintiff's Lawyers Brouillette, Amanda Nicole (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-9000
Caldas, Tamara S. (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Cassler, Rebecca (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Chavez, Paul (Florida) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Crow, Melissa E. (District of Columbia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Gilfillan, Doug (Georgia) show/hide docs
IM-GA-0016-9000
Isted, Kathryn E (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Li, Hillary (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Mesa-Estrada, Victoria (Florida) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Nguyen, Phi U. (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Sandley, Caitlin J. (Alabama) show/hide docs
IM-GA-0016-9000
Williams, Lorilei (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Willis, Gracie Harper (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Woodard, Tayah (Georgia) show/hide docs
IM-GA-0016-0001 | IM-GA-0016-0003 | IM-GA-0016-0004 | IM-GA-0016-9000
Defendant's Lawyers Helmick, Amelia G. (Georgia) show/hide docs
IM-GA-0016-0002 | IM-GA-0016-9000
Peeler, Charles E. (Georgia) show/hide docs
IM-GA-0016-0002
Shoemaker, E. Bowen Reichert (Georgia) show/hide docs
IM-GA-0016-0002 | IM-GA-0016-9000
Simon, Lance (Georgia) show/hide docs
IM-GA-0016-9000
Snell, Bernard (Georgia) show/hide docs
IM-GA-0016-0002 | IM-GA-0016-9000
Struck, Daniel Patrick (Arizona) show/hide docs
IM-GA-0016-9000

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