Third Circuit: Failure to Make PLRA Findings Moots Appeal
by David M. Reutter
The Third Circuit Court of Appeals held that a district court’s failure to make findings as to the Prison Litigation Reform Act’s (PLRA) “needs-narrowness-intrusiveness criteria” mooted all injunctive enforcement actions that occurred 90 days after the court entered a preliminary injunction.
The ruling came in an appeal brought by Pennsylvania’s Berks County Prison. As previously reported, the federal district court issued a preliminary injunction in a class-action suit that alleged female prisoners classified as trustees were treated differently than male trustees. [See: PLN, Dec. 2019, p.17].
The injunction required jail officials to create and implement a plan to assure the female prisoners received similar conditions of confinement as males. The court entered orders on July 1 and July 16, 2019, first requiring the jail to file a plan to comply with the initial injunction, then to implement the plan once filed. After failing to comply with the first order, the defendants were held in contempt. The county filed four separate appeals.
Under the PLRA, a district court cannot “grant or approve any prospective relief” regarding prison conditions “unless the court finds that such relief is narrowly drawn, extends no further than necessary to correct violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.” The PLRA also provides that a preliminary injunction expires “90 days after its entry” unless the court makes the required needs-narrowness-intrusiveness findings and enters a final order.
The Third Circuit held on October 11, 2019 that on neither of the two occasions that the district court entered a preliminary injunction did it make the required findings for the order to extend beyond 90 days. As such, those injunctions expired after that time period. Since the initial injunction was not in effect when the contempt order was issued, that order was invalid and reversed by the appellate court.
The Court of Appeals then found the interlocutory appeals were moot and that it was unable to grant the additional relief requested by the county. The appeal was dismissed and the matter remanded to the district court. See: Victory v. Berks County, 2019 U.S. App. LEXIS 30520 (3d Cir. 2019).
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Related legal case
Victory v. Berks County
|Cite||2019 U.S. App. LEXIS 30520 (3d Cir. 2019)|
|Level||Court of Appeals|