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Case Name Grinis v. Spaulding PC-MA-0054
Docket / Court 1:20-cv-10738 ( D. Mass. )
State/Territory Massachusetts
Case Type(s) Prison Conditions
Special Collection COVID-19 (novel coronavirus)
Attorney Organization ACLU Chapters (any)
ACLU National (all projects)
Case Summary
COVID-19 Summary: This was a habeas action filed on behalf of a class of prisoners at the Federal Medical Center Devens in Massachusetts, seeking the release of inmates in light of COVID-19 so that the facility could properly socially distance. The court denied the temporary restraining order and ... read more >
COVID-19 Summary: This was a habeas action filed on behalf of a class of prisoners at the Federal Medical Center Devens in Massachusetts, seeking the release of inmates in light of COVID-19 so that the facility could properly socially distance. The court denied the temporary restraining order and preliminary injunction on May 8, 2020 and dismissed the action on July 2, 2020.


Three federal prisoners at the Federal Medical Center, Devens, Massachusetts filed this class-action habeas corpus petition in the U.S. District Court for the District of Massachusetts on April 15, 2020. Alarmed by the rapid spread of COVID-19 in prisons across the country, the plaintiffs sought the release of enough inmates from FMC Devens that the remaining inmates would be able to maintain 6 feet of social distancing at all times, as recommended by the Centers for Disease Control. Represented by the ACLU, the ACLU of Massachusetts, and private counsel, they argued that their continued detention, with the high likelihood of a deadly outbreak sweeping through the prison, was cruel and unusual punishment in violation of the Eighth Amendment. The petition pointed to the CARES Act, as well as guidance from Attorney General William Barr, instructing federal prisons to expand the use of compassionate release and home confinement to reduce prison populations during the pandemic.

The plaintiffs sought to represent a class of all inmates in custody at FMC Devens; a subclass of inmates at high risk of injury or death from COVID-19; and a subclass of inmates who could qualify for early transfer to home confinement. For themselves and for the class, they sought declaratory judgment, and requested a special master to oversee the prison’s compliance with the order.

On April 24, 2020, the court denied approximately 2 dozen individual requests to be “added as a class member,” because no class had been certified.

On May 4, 2020, a member of the proposed class died of COVID-19 at FMC Devens. On May 5, Plaintiff Grinis was transferred to home confinement by order of his sentencing judge (criminal case 18-cr-10206), to serve the remaining 6 weeks of his sentence.

Skeptical of the claim that the prison’s failure to de-densify would amount to cruel and unusual punishment, the court denied the plaintiffs’ motion for temporary restraining order or preliminary injunction. In that order, dated May 8, 2020, the court also indicated that there was “a substantial question” regarding whether habeas corpus was the proper source for the relief that the plaintiffs sought. 2020 WL 2300313

This “substantial question” was answered on June 11, 2020, when the court ruled that the action was improperly brought as a habeas petition. Although a habeas petition in name, the action was in reality a civil claim governed by the Prison Litigation Reform Act (PLRA). The court held that unless the plaintiffs reframed their complaint and proceeded under the PLRA, the action would be dismissed. 2020 WL 3097360

On June 18, 2020, the plaintiffs declined the court’s invitation to reframe their complaint. Even if it were legally appropriate to proceed under the PLRA, the pandemic’s rapid spread would make it impossible to obtain relief quickly enough to protect their lives and health. They asked the court to vacate its ruling of May 8, arguing that since the court had ruled that it did not have jurisdiction, it should not have addressed the merits of their habeas petition at all.

On July 2, 2020, the court dismissed the action, clarifying that it did have jurisdiction over any habeas petition brought before the court; the petition had been dismissed because the plaintiffs had not properly stated a claim under §2241 and declined to vacate the earlier judgment. As of September 23, 2020, the plaintiffs have not appealed the ruling.

Gregory Marsh - 07/28/2020


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Suspension Clause
Content of Injunction
Preliminary relief denied
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Conditions of confinement
Over/Unlawful Detention
Sanitation / living conditions
Medical/Mental Health
COVID-19 Mitigation Denied
COVID-19 Mitigation Requested
COVID-19 Release Denied
COVID-19 Release Requested
Special Case Type
Habeas
Type of Facility
Government-run
Causes of Action Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255
Defendant(s) Federal Medical Facility Devens
Plaintiff Description Prisoners at Federal Medical Center Devens, seeking compassionate release or transfer to home confinement as a result of the COVID-19 pandemic, and others similarly situated.
Indexed Lawyer Organizations ACLU Chapters (any)
ACLU National (all projects)
Class action status sought Yes
Class action status granted No
Filed Pro Se No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Filed 2020
Case Ongoing Yes
Additional Resources
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  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
  Grinis v. Spaulding
https://www.aclum.org
Date: May 8, 2020
By: American Civil Liberties Union Massachusetts
[ Detail ] [ External Link ]

Docket(s)
1:20-cv-10738-GAO (D. Mass.)
PC-MA-0054-9000.pdf | Detail
Date: 07/02/2020
Source: PACER [Public Access to Court Electronic Records]
General Documents
Petition for Writ of Habeas Corpus Under 28 U.S.C. § 2241 and Complaint for Injunctive and Declaratory Relief [ECF# 1]
PC-MA-0054-0001.pdf | Detail
Date: 04/15/2020
Source: PACER [Public Access to Court Electronic Records]
Motion for Immediate Bail Consideration, Temporary Restraining Order, and Preliminary Injunctive Relief [ECF# 3]
PC-MA-0054-0002.pdf | Detail
Date: 04/15/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum in Support of Motion for Immediate Bail Consideration, Temporary Restraining Order, and Preliminary Injunctive Relief [ECF# 4 (& 4-1 to 4-4)]
PC-MA-0054-0013.pdf | Detail
Date: 04/15/2020
Source: PACER [Public Access to Court Electronic Records]
Petitioners' Motion for Class Certification or Representative Habeas Action [ECF# 5]
PC-MA-0054-0003.pdf | Detail
Date: 04/15/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum in Support of Petitioners' Motion for Class Certification or Representative Habeas Action [ECF# 6]
PC-MA-0054-0014.pdf | Detail
Date: 04/15/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Omnibus Response to Petition for Writ of Habeas Corpus and Opposition to Petitioners' Motion for Immediate Bail and Injunctive and Declaratory Relief [ECF# 32]
PC-MA-0054-0004.pdf | Detail
Date: 04/22/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum for Director of Bureau Prisons [ECF# 32-3]
PC-MA-0054-0015.pdf | Detail
Date: 04/22/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum for Director of Bureau of Prisons [ECF# 32-4]
PC-MA-0054-0016.pdf | Detail
Date: 04/22/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Supplemental Declaration [ECF# 36]
PC-MA-0054-0017.pdf | Detail
Date: 04/24/2020
Source: PACER [Public Access to Court Electronic Records]
Petitioners' Reply to Respondents' Omnibus Response [ECF# 38 (& 38-1, 38-4, 38-5, 38-7) ]
PC-MA-0054-0018.pdf | Detail
Date: 04/27/2020
Source: PACER [Public Access to Court Electronic Records]
Notice of Supplemental Authorities and Information [ECF# 40]
PC-MA-0054-0005.pdf | Detail
Date: 04/30/2020
Source: PACER [Public Access to Court Electronic Records]
Second Notice of Supplemental Authorities and Information [ECF# 41]
PC-MA-0054-0006.pdf | Detail
Date: 05/04/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Notice of Supplemental Authority [ECF# 43]
PC-MA-0054-0007.pdf | Detail
Date: 05/07/2020
Source: PACER [Public Access to Court Electronic Records]
Opinion and Order [ECF# 45] (2020 WL 2300313) (D. Mass.)
PC-MA-0054-0008.pdf | WESTLAW | Detail
Date: 05/08/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Notice Regarding Petitioner Alexander Grinis [ECF# 48]
PC-MA-0054-0019.pdf | Detail
Date: 05/12/2020
Source: PACER [Public Access to Court Electronic Records]
Third Notice of Supplemental Authorities and Information [ECF# 51]
PC-MA-0054-0009.pdf | Detail
Date: 05/14/2020
Source: PACER [Public Access to Court Electronic Records]
Memorandum in Support of Petitioners' Motion to Reconsider the Court's May 8, 2020 Decision Denying Preliminary Relief [ECF# 53]
PC-MA-0054-0020.pdf | Detail
Date: 05/27/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Second Notice of Supplemental Authority [ECF# 54]
PC-MA-0054-0010.pdf | Detail
Date: 05/27/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Opposition to Petitioners' Motion for Reconsideration [ECF# 58 (& 58-1, 58-2)]
PC-MA-0054-0011.pdf | Detail
Date: 06/09/2020
Source: PACER [Public Access to Court Electronic Records]
Respondents' Notice of Supplemental Authority [ECF# 59]
PC-MA-0054-0021.pdf | Detail
Date: 06/10/2020
Source: PACER [Public Access to Court Electronic Records]
Opinion and Order [ECF# 60] (2020 WL 3097360) (D. Mass.)
PC-MA-0054-0022.pdf | WESTLAW | Detail
Date: 06/11/2020
Source: PACER [Public Access to Court Electronic Records]
Petitioners' Response to Courts June 11, 2020 Order and Motion to Clarify or, Alternatively, to Vacate Courts May 8, 2020 Order [ECF# 61]
PC-MA-0054-0023.pdf | Detail
Date: 06/18/2020
Source: PACER [Public Access to Court Electronic Records]
Order of Dismissal [ECF# 63] (D. Mass.)
PC-MA-0054-0012.pdf | Detail
Date: 07/02/2020
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Bumb, Renee Marie (D.N.J.) show/hide docs
PC-MA-0054-0010
O'Toole, George A. Jr. (D. Mass.) show/hide docs
PC-MA-0054-0008 | PC-MA-0054-0012 | PC-MA-0054-0022 | PC-MA-0054-9000
Sotomayor, Sonia (S.D.N.Y., Second Circuit, SCOTUS) show/hide docs
PC-MA-0054-0011
Plaintiff's Lawyers Barsky, Amy (Massachusetts) show/hide docs
PC-MA-0054-0001 | PC-MA-0054-0002 | PC-MA-0054-0003 | PC-MA-0054-0005 | PC-MA-0054-0006 | PC-MA-0054-0009 | PC-MA-0054-0013 | PC-MA-0054-0014 | PC-MA-0054-0018 | PC-MA-0054-0020 | PC-MA-0054-0023 | PC-MA-0054-9000
Fick, William W (Massachusetts) show/hide docs
PC-MA-0054-0001 | PC-MA-0054-0002 | PC-MA-0054-0003 | PC-MA-0054-0005 | PC-MA-0054-0006 | PC-MA-0054-0009 | PC-MA-0054-0013 | PC-MA-0054-0014 | PC-MA-0054-0018 | PC-MA-0054-0020 | PC-MA-0054-0023 | PC-MA-0054-9000
Marx, Daniel N (Massachusetts) show/hide docs
PC-MA-0054-0001 | PC-MA-0054-0002 | PC-MA-0054-0003 | PC-MA-0054-0005 | PC-MA-0054-0006 | PC-MA-0054-0009 | PC-MA-0054-0013 | PC-MA-0054-0014 | PC-MA-0054-0018 | PC-MA-0054-0020 | PC-MA-0054-0023 | PC-MA-0054-9000
Rossman, Jessie J. (Massachusetts) show/hide docs
PC-MA-0054-0001 | PC-MA-0054-0002 | PC-MA-0054-0003 | PC-MA-0054-0005 | PC-MA-0054-0006 | PC-MA-0054-0009 | PC-MA-0054-0013 | PC-MA-0054-0014 | PC-MA-0054-0018 | PC-MA-0054-0020 | PC-MA-0054-0023 | PC-MA-0054-9000
Segal, Matthew (Massachusetts) show/hide docs
PC-MA-0054-0001 | PC-MA-0054-0002 | PC-MA-0054-0003 | PC-MA-0054-0005 | PC-MA-0054-0006 | PC-MA-0054-0009 | PC-MA-0054-0013 | PC-MA-0054-0014 | PC-MA-0054-0018 | PC-MA-0054-0020 | PC-MA-0054-0023 | PC-MA-0054-9000
Defendant's Lawyers Barr, William P. (District of Columbia) show/hide docs
PC-MA-0054-0015 | PC-MA-0054-0016
Lelling, Andrew E. (Massachusetts) show/hide docs
PC-MA-0054-0004 | PC-MA-0054-0007 | PC-MA-0054-0010 | PC-MA-0054-0011 | PC-MA-0054-0017 | PC-MA-0054-0019 | PC-MA-0054-0021
Piemonte-Stacy, Eve (Massachusetts) show/hide docs
PC-MA-0054-0004 | PC-MA-0054-0007 | PC-MA-0054-0010 | PC-MA-0054-0011 | PC-MA-0054-0017 | PC-MA-0054-0019 | PC-MA-0054-0021 | PC-MA-0054-9000

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