Rice v. Gonzalez

Summary

**Rice v. Gonzalez, 5th Cir. 2021** – Habeas corpus relief under 28 U.S.C. § 2241 is not available to challenge conditions of confinement, even during the COVID-19 pandemic. The Fifth Circuit held that a pretrial detainee's claim that jail conditions posed a health risk due to COVID-19 did not attack the fact or duration of his custody, and thus could not proceed via habeas. Such conditions-of-confinement claims must be brought under 42 U.S.C. § 1983, not habeas corpus. The court affirmed dismissal for failure to state a claim.

Holdings

1. Habeas corpus relief is not available for conditions of confinement claims; such claims must be brought under 42 U.S.C. § 1983.

Questions Presented

1. Whether a pretrial detainee's conditions-of-confinement claim can be raised in a habeas corpus petition under 28 U.S.C. § 2241.

Disposition

affirmed