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Keywords

injunctionmotionleasedue process
plaintifflitigationinjunctionmotionleasebaildue processdeportation

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Savino v. Souza

Facts

The case involved a class of civil immigration detainees held at the Bristol County House of Correction who claimed that the facility's overcrowded and unsanitary conditions violated their due process rights amid the COVID-19 pandemic. The detainees filed a motion for a temporary restraining order, which was converted into a motion for a preliminary injunction. The court had previously released a significant number of detainees to reduce crowding, but the government continued to oppose further releases and resisted widespread testing.

The named plaintiffs-petitioners are two of 148 individuals (the 'Detainees') detained by Immigration and Customs Enforcement ('ICE') on civil immigration charges who, at the start of this litigation, were held at the Bristol County House of Correction ('BCHOC') in North Dartmouth, Massachusetts.

Issue

Whether the conditions of confinement for immigration detainees during the COVID-19 pandemic constituted a violation of their due process rights, warranting a preliminary injunction.

Whether the conditions of confinement for immigration detainees during the COVID-19 pandemic constituted a violation of their due process rights, warranting a preliminary injunction.

Rule

The court applied the standard for granting a preliminary injunction, which requires a substantial likelihood of success on the merits, a significant risk of irreparable harm, a favorable balance of hardships, and a fit between the injunction and the public interest.

'Crafting a preliminary injunction is an exercise of discretion and judgment, often dependent as much on the equities of a given case as the substance of the legal issues it presents.'

Analysis

The court found that the detainees demonstrated a likelihood of irreparable harm due to the government's deliberate indifference to the substantial risk of serious harm posed by COVID-19. The court noted that the government's minimal efforts at testing and contact tracing, combined with its opposition to releasing detainees, indicated a failure to adequately protect the health of those in custody. The balance of equities favored the detainees, as the injunction would help mitigate the risk of an outbreak.

As explained more fully below, the Court reaches three essential conclusions. First, withholding this preliminary injunction would likely cause the detainees irreparable harm because some number of them would get seriously ill or die. Second, the government's response likely amounts to deliberate indifference to a substantial risk of serious harm to the detainees' health. This deliberate indifference is proven by the government's near-blanket opposition to the release of detainees throughout the bail process (though it did somewhat reduce the population through limited bond releases and deportations), as well as by its minimal efforts at testing and contact tracing.

Conclusion

The court granted the motion for a preliminary injunction, ordering the government to test all detainees and staff and to stop admitting new detainees to the facility.

The Court then turned to the pending motion for a preliminary injunction and, after briefing and oral argument, preliminarily ordered the government (1) to test all detainees and staff who come into contact with them; and (2) not to admit any more detainees to this facility.

Who won?

The detainees prevailed in the case because they successfully demonstrated the likelihood of irreparable harm and the government's failure to protect their health during the pandemic.

The detainees prevailed in the case because they successfully demonstrated the likelihood of irreparable harm and the government's failure to protect their health during the pandemic.

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