Larry Craig v. D. Reagle, Warden, et al.

Summary

The United States District Court for the Southern District of Indiana granted defendants' motions for summary judgment in Larry Craig's Eighth Amendment action concerning restricted outdoor recreation at Pendleton Correctional Facility. The court held that COVID-19 quarantines and staffing shortages did not establish a constitutional violation and that defendants were alternatively entitled to qualified immunity. Final judgment was directed to issue separately.

Holdings

1. The temporary limitation of outdoor recreation caused by COVID-19 quarantines and unavoidable staffing shortages did not violate Craig's Eighth Amendment rights where the restrictions were applied across the housing unit, were based on safety and disease-control concerns, and Craig did not show that he was unable to exercise in his cell.
2. Defendants were entitled to qualified immunity because Craig did not identify clearly established Supreme Court or Seventh Circuit authority placing officials on notice that restricting outdoor recreation to prevent the spread of a novel communicable disease violated the Eighth Amendment.
3. Craig's speculation that defendants created false quarantines or artificial staffing shortages was insufficient to create a genuine dispute of material fact.

Questions Presented

1. Whether COVID-19-related quarantines and staffing shortages that limited Craig's outdoor recreation violated the Eighth Amendment.
2. Whether defendants were entitled to qualified immunity because their conduct did not violate a clearly established constitutional right.
3. Whether defendants were entitled to summary judgment because Craig relied only on speculation to dispute the legitimacy of the quarantines and staffing shortages.

Disposition

other