Summary
The Supreme Court denied a petition for a writ of certiorari concerning a prison-construction injunction involving New Orleans inmates with mental-health needs. Justice Gorsuch would have granted review, and Justice Alito, joined by Justice Thomas, dissented, asserting that the injunction violated the Prison Litigation Reform Act and that the lower courts improperly allocated the burden on a motion to terminate prospective relief.
Topics
Practice areas
Questions Presented
- Whether the Supreme Court should review the Fifth Circuit's treatment of an injunction allegedly barred by the Prison Litigation Reform Act.
- Whether the injunction was subject to immediate termination because it violated 18 U.S.C. § 3626(a)(1)(C).
- Whether the injunction was terminable two years after issuance under 18 U.S.C. § 3626(b)(1)(A)(i), and which party bore the burden under § 3626(b)(3) of showing that continued prospective relief was justified.
Key quotations
“The petition for a writ of certiorari is denied.” (1)
“Yet the Prison Litigation Reform Act of 1995 (PLRA) specifically states that “[n]othing in this section shall be construed to authorize the courts, in exercising their remedial powers, to order the construction of prisons.”” (1)
“It was not the sheriff’s burden to provide a basis for termination; it was the opposing parties’ burden to show a basis for maintaining the injunction.” (2)
Factual background
In 2019, a district court ordered New Orleans to construct a new facility for inmates with mental-health needs. The injunction was challenged under the Prison Litigation Reform Act, which prohibits courts from ordering prison construction and provides for termination of prospective relief under specified circumstances. Four years after the injunction was granted, the New Orleans sheriff moved to terminate orders concerning construction of the Phase III jail, but the lower courts denied the motion.
Procedural history
The lower courts declined to terminate a prison-construction injunction concerning a New Orleans facility for inmates with mental-health needs. The Supreme Court denied certiorari. Justice Gorsuch would have granted review, and Justice Alito, joined by Justice Thomas, dissented from the denial.