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Articles by Matthew Clarke

Dissenter Excoriates SCOTUS for Denying Certiorari in Challenge to Constitutionality of Nitrogen Hypoxia Execution

On October 23, 2025, the Supreme Court of the United States (SCOTUS) denied certiorari in a federal civil rights action challenging Alabama’s use of nitrogen hypoxia for executions. Justice Sonia Sotomayor wrote a vivid and strongly worded dissent joined by Justices Elena Kagan and Ketanji …

D.C. Federal Court Holds Blocking Prison Reform Advocate’s Access to Federal Prisoners May Violate First Amendment and Due Process

On April 12, 2025, the United States District Court for the District of Columbia denied the government’s motion to dismiss with respect to due process and First Amendment claims made by a federal prison reform advocate whose access to communicate via electronic messaging with prisoners …

Eleventh Circuit Holds Estate Cannot Sue Jailers Who Followed Medical Personnel Advice That Led to Detainee’s Death

by Matt Clarke

On December 1, 2025, the United States Court of Appeals for the Eleventh Circuit held that jailers could not be held liable for the death of a Georgia pretrial detainee caused by lack of medical care. The Court’s rationale was that the jailers followed the …

Sixth Circuit Reinstates Lawsuit Over Failure to Properly Classify Violent Prisoners at Kentucky Jail

by Matt Clarke

On December 17, 2025, the United States Court of Appeals for the Sixth Circuit reinstated a federal civil rights lawsuit brought by the guardian of a man who was severely injured when two prisoners with lengthy histories of assaulting other prisoners and jail staff severely …

Eleventh Circuit Holds Alabama County May Be Liable for Policy of Providing Inadequate Jail Medical Care

by Matt Clarke

On November 20, 2025, the United States Court of Appeals for the Eleventh Circuit held that an Alabama law making sheriffs responsible for jail prisoners’ health care did not excuse a county from liability for having a policy resulting in inadequate prisoner health care. The …

Tenth Circuit Reverses Summary Dismissal of Claim Over Prisoner’s Suicide in Oklahoma Jail

On November 26, 2025, the United States Court of Appeals for the Tenth Circuit reversed the summary dismissal of a failure-to-train claim in a federal civil rights lawsuit over the suicide of an in-transit federal prisoner being held overnight in an Oklahoma jail.

In …

Deportation of Kenyan Priest Working as Texas Prison Guard Highlights TDCJ’s Dependence on Immigrant Staff

by Matt Clarke

The Rev. James Eliud Ngahu Mwangi, an Episcopal priest, was working as a prison guard in the Texas Department of Criminal Justice (TDCJ) until federal Immigration and Customs Enforcement (ICE) declared him a deportable alien and detained him as he returned home from work on …

Ninth Circuit Reinstates Wheelchair-Bound Washington State Prisoner’s Suit Over Failure to Accommodate Disabilities During Transport

by Matt Clarke

On December 19, 2025, the United States Court of Appeals for the Ninth Circuit reinstated a federal civil rights lawsuit brought by a wheelchair-bound Washington State Department of Corrections (DOC) prisoner who was forcibly placed on a standard prison transport bus instead of a special …

Eleventh Circuit Upholds Dismissal of Six Female Alabama Jail Detainees’ Sexual Assault Suit

by Matt Clarke

On October 17, 2025, the United States Court of Appeals for the Eleventh Circuit upheld a district court’s summary dismissal of a federal civil rights suit brought by six women who were allegedly sexually assaulted while incarcerated at an Alabama jail because the lawsuit failed …

California Funds $38 Million Pilot Program to Investigate Methods for Cooling Three Prisons

by Matt Clarke

The California Department of Corrections and Rehabilitation (CDCR) recently announced a pilot program to study the use of various types of cooling systems and new insulation at three prisons to determine the best methods for wider application within its 31-­prison system. Currently, only around 8,000 …