First Circuit Revives Federal Prisoner’s Claim Against Rhode Island Lockup
by Chuck Sharman
When a prisoner is held in a state facility to await sentencing on federal charges, does that confer federal immunity on the lockup? That was the question presented to the U.S. Court of Appeals for the First Circuit in the appeal of David Daoud Wright, after the U.S. District Court for the District of Rhode Island granted derivative federal immunity to the Wyatt Detention Facility (WDF) and dismissed his civil rights claims against officials employed there.
Wright was held at the WDF for 17 months after his January 2020 conviction on federal charges before his sentencing in June 2021. During that period, he told officials of his desire for religious “services,” “programming” and “property” that was consistent with his Sunni Muslim faith. But as the appellate Court later recalled, “Wyatt officials told Wright ‘that his religious adherence was problematic’ and subjected him to ‘harassment’ and ‘insults,’” he said.
Wright then filed his pro se complaint in the district court in January 2024, proceeding under 42 U.S.C. § 1983 to accuse then-Warden Daniel Martin and other prison officials of violating his civil rights. Defendants moved to dismiss, claiming derivative federal immunity. The district court agreed and granted the motion, pointing to Glennie v. Garland, 2023 U.S. Dist. LEXIS 32771 (D.R.I.), a February 2023 decision that granted WDF officials federal immunity from § 1983 claims which were filed by a federally convicted prisoner awaiting sentencing.
Despite the similarity between the two cases, Wright turned to the First Circuit, and the appellate Court said, in effect, not so fast. First, the cases on which Glennie relied were brought by prisoners against WDF when it was privately owned. Since 2007, however, WDF has been owned by the Central Falls Detention Facility Corp. (CFDFC), which was created by the Rhode Island legislature. Per its authorizing legislation, CFDFC is a public facility, the Court noted. Moreover, it is financed with bonds underwritten and sold by the Rhode Island Port Authority and Economic Development Corporation.
Meaning that Martin was an employee of a public corporation operated as an agency of the City of Central Falls, “governed by board members appointed by the city’s mayor and approved by its city council”—in other words, the First Circuit said, “the CFDFC appears simply to be an extension of the City of Central Falls itself.” Martin objected that the CFDFC built the WDF with the intention of holding federal detainees and prisoners for the U.S. Marshals Service. But the Court noted that it “is not required exclusively to house federal inmates.” Therefore, the Court continued, it did “not see how the Act’s purpose supports Martin’s contention that Wyatt is a federal facility notwithstanding its decidedly municipal attributes.”
Martin attempted to argue that the lockup could not be municipal for Wright, because he was a federal prisoner. But the First Circuit failed to recognize that distinction and “agree[d] with our sister circuits that the mere fact of a contract to house federal detainees does not transform a municipally owned and operated facility into a federal … one, or a municipal employee into a federal actor.” Accordingly, the district court’s decision was vacated and the case remanded. Before the Court, Wright was represented by Providence attorney Amato A. DeLuca of DeLuca, Weizenbaum, Barry & Revens, Ltd. See: Wright v. Martin, 158 F.4th 286 (1st Cir. 2025).
Back at the district court, DeLuca was appointed to continue providing pro bono counsel to Wright, on whose behalf he filed an amended complaint in February 2026, and Defendants answered the following month. The case remains open, and PLN will continue to update developments. See: Wright v. Martin, USDC (D.R.I.), Case No. 1:24-cv-0019.
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Related legal case
Wright v. Martin
| Year | 2027 |
|---|---|
| Cite | 158 F.4th 286 (1st Cir. 2025) |
| Level | Court of Appeals |