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Articles by David Reutter

Over $298,000 Awarded to Alabama Jail Detainee with Heart Disease After Guards, Nurses Ignored Firing Defibrillator

by David M. Reutter

After a federal jury awarded $135,000 to an Alabama man deprived of medical care for a heart condition while detained at the Autauga County Jail (ACJ), the U.S. District Court for the Middle District of Alabama awarded another $163,268.25 in fees and expenses to his attorney ...

$857,500 Paid by California County for Jail Detainee’s Death, While Cellmate Who Beat Him Is Now in State Prison

by David M. Reutter

On August 17, 2022, Lager George Reid, 26, was admitted to Folsom State Prison, after he pleaded guilty to manslaughter in the death of his cellmate at the jail in California’s San Bernardino County. Reid was being held at the county’s West Valley Detention Center (WVDC) ...

After Eleventh Circuit Says ICE Detainee Is Not “Prisoner” Subject to PLRA, He Goes Missing from Georgia

by David M. Reutter

On September 29, 2022, the U.S. Court of Appeals for the Eleventh Circuit held that a civil detainee in custody of federal Immigration and Customs Enforcement (ICE) is not a “prisoner” subject to the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e. Since that law ...

Ninth Circuit Says Statements Relayed at Criminal Trial By Nurse and Doctor Are Admissible, Not Hearsay

by David M. Reutter

When is hearsay evidence not hearsay? On August 31, 2022, the U.S. Court of Appeals for the Ninth Circuit provided its answer. Affirming the conviction of a federal prisoner in Hawaii for assaulting a fellow prisoner, the Court said that statements from the victim reported by ...

Fourth Circuit Reinstates Virginia Prisoner’s Spoliation Motion for Lost Video of His Alleged Assault by Guards

by David M. Reutter

On July 25, 2022, the U.S. Court of Appeals for the Fourth Circuit held that a district court in Virginia abused its discretion by implicitly overruling a prisoner’s spoliation objections when several critical issues were left unresolved by the magistrate judge.

The Court’s opinion was issued ...

Seventh Circuit: Indiana Prisoner Who Failed to Formalize Grievance Also Failed to Exhaust Remedies

by David M. Reutter

On August 17, 2022, an Indiana prisoner learned a painful lesson from the U.S. Court of Appeals for the Seventh Circuit. As PLN has repeatedly warned, courts are empowered by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, to dismiss any lawsuit filed by ...

Record Deaths at Rikers Island Blamed on Guards’ Absenteeism, Abuse and Corruption

by Anthony W. Accurso and David M. Reutter

After 16 detainee deaths in 2021[See: PLN, Feb. 2022, p.1], the carnage continued at New York City’s Rikers Island jail complex in 2022, leaving 19 more people dead. Having recorded an average of just six deaths a year from 2017 through ...

Third Circuit Strips Qualified Immunity From Delaware Guards Who Held Mentally Ill Prisoner in Solitary for Seven Months

by David M. Reutter

In a decision filed on November 28, 2022, the U.S. Court of Appeals for the Third Circuit reversed the grant of qualified immunity (QI) to Delaware prison officials in a lawsuit brought by a mentally ill prisoner held in solitary confinement for seven months, alleging they ...

Florida Jailers Leave Detainees Out of Evacuation Plans During Hurricane

by David M. Reutter

On September 28, 2022, as Hurricane Ian bore down on Florida and neared Category 5 strength, the state Department of Corrections (DOC), which holds about 80,000 prisoners, began evacuating 2,300 of them from 23 prisons statewide. But some lockups in the storm’s path took little action: Rather ...

Ninth Circuit Revives Failure-to-Protect Claim of Arizona Prisoner Beaten by Gang

by David M. Reutter

On July 5, 2022, the U.S. Court of Appeals for the Ninth Circuit held that giving a jury a standard instruction to defer to prison officials was error when the jury needed to decide whether prison officials failed to protect a prisoner from violence.

Before the ...