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Prison Legal News: August, 2025

Issue PDF
Volume 36, Number 8

In this issue:

  1. Now Under Federal Receivership, 
New York City’s Rikers Island Jails Still Have 
No Plan to Improve, No Firm Date to Close (p 1)
  2. From the Editor (p 9)
  3. Watchdog Calls Out D.C. for Dragging Feet 
on Construction of New Jail (p 10)
  4. $75,000 for Transgender Maryland Prisoner Raped by Guard (p 11)
  5. Texas Social Workers Challenge Blanket Denial of State Occupational License Based on Youthful Assault Convictions (p 11)
  6. CDCR Held in Contempt, Fined $112 Million 
in Longstanding Litigation Over Mental Health Care (p 12)
  7. Two Exonerated Illinois Prisoners Win Settlements 
Totaling $14.5 Million (p 13)
  8. California Prisoners Sue Gynecologist for Sexual Abuse (p 14)
  9. $2.6 Million Paid for Detoxing Washington Jail Detainee Allowed 
to Leap to His Death, Additional NaphCare Payout Undisclosed (p 15)
  10. Oklahoma Prisoner’s Execution Was Expedited 
by the Trump Administration (p 15)
  11. Multiple Prisoner Suits Accuse Guards of Violence 
at Virginia BOP Lockup (p 16)
  12. Sixth Circuit Holds Dismissal Not Automatic When Plaintiff Simultaneously Files Same Claims in State Court (p 17)
  13. Alabama DOC Attorneys Reprimanded for 
Filing AI-Written Briefs in Prisoner’s Suit (p 18)
  14. FCC Backtracks on 2024 Order to Cut 
Prison Phone and Video Rates by Half (p 19)
  15. Nebraska Considers Curbing Double-Bunking 
in Restrictive Housing (p 19)
  16. $1.2 Million for New York Prisoner Waterboarded by Guards (p 20)
  17. Former Maine Prison Guard Arrested 
and Detained by ICE Agents (p 20)
  18. $15 Million Settlement Reached in San Diego Jail Detainee’s Untreated Withdrawal Death (p 21)
  19. $6.75 Million Settlement Reached in Suit Accusing 
Massachusetts Guards of Retaliatory Assaults on Prisoners (p 22)
  20. Missouri Prison Nurse Sentenced 
to 12 Years for Poisoning Husband (p 23)
  21. Fifth Circuit Greenlights Federal Takeover of Mississippi Jail (p 24)
  22. $325,000 Paid to Former Wisconsin Prisoner Whose Cancer Biopsy Was Delayed by Previously Disciplined Doctor (p 25)
  23. Texas Lawmakers Restrict Bail and Raise Criminal Penalties, 
Punt on Prison and Jail Conditions (p 26)
  24. SCOTUS Partially Overturns Pavey, Holds PLRA Exhaustion 
Dispute Must Go to Jury Even If Intertwined with 
Merits of Michigan Prisoner’s Claim (p 26)
  25. PLN Publisher Wins Settlement Records from Centurion 
in Florida Prisoner’s Wrongful Death (p 27)
  26. Prison Gerrymandering 
Alive and Well in Oklahoma (p 29)
  27. After Judge’s Letter, at Least 22 Former FCI Dublin Prisoners Granted Compassionate Release (p 29)
  28. Ninth Circuit Revives Prisoner’s Claim Based on Guard’s 
Thwarting of Administrative Remedies (p 30)
  29. $815,000 Settlement in Nevada Class-Action Suit 
Over Debit Release Cards (p 30)
  30. Review: “Reforming the Shadow Carceral State” (p 33)
  31. Fourth Circuit Revives Wrongful Conviction Claim of Exonerated Maryland Prisoner, State Pays Him $3.1 Million (p 34)
  32. HRDC Wins $480,000 in Legal Fees from Centurion for Denied New Mexico Records (p 35)
  33. Costs of U.S. Incarceration to Families
Pegged at Nearly $350 Billion a Year (p 36)
  34. DOJ Tables Controversial Kentucky Prison 
to Claw Back $500 Million Budget (p 36)
  35. $3,800 Paid to Ohio Prisoner for Denied Records Request (p 37)
  36. Delaware’s ACLU Files Action on Behalf Of Six Prisoners 
Assaulted During Midnight Raid (p 38)
  37. DOJ Finds Unconstitutional Conditions in Texas Juvenile Detention (p 38)
  38. HRDC Collaborates on Prison Telecom Cost Report 
to Washington Lawmakers (p 39)
  39. Over Eight Years in Prison for iCare Founder Who Ran Prisoner Gift Basket Scam (p 40)
  40. Suit Filed Over Fatal Beating of New York Prisoner 
That Sparked Massive Guard Strike (p 40)
  41. Life Sentences, by the Numbers (p 41)
  42. Sixth Circuit Upholds $45 Million Verdict for 
Wrongfully Convicted Former Ohio Prisoner (p 43)
  43. Former California Prison Guard 
Pleads Guilty to Planting Contraband 
He Pretended to Discover (p 43)
  44. Tenth Circuit Ruling Paves Way for $2.7 Million Settlement 
for Intellectually Disabled Jail Detainee Raped by Sheriff (p 44)
  45. SCOTUS Clamps Down on Bivens Extension to Prisoner 
Beaten by BOP Guards at Virginia Lockup (p 46)
  46. Ninth Circuit Agrees That Former Guantanamo Detainee 
Lacks Grounds to Sue for Waterboarding (p 48)
  47. $1.875 Million Partial Settlement for Colorado Detainee’s 
Death from Untreated Alcohol Withdrawal; 
Claims Against Wellpath Pending Bankruptcy (p 49)
  48. $95,000 Paid to Nevada Prisoner Denied 
Muslim Prayer; Pending Cases Allege Continued 
Discrimination Against Non-Protestants (p 50)
  49. On Remand, Eleventh Circuit Clarifies, Affirms Grant 
of Habeas Relief to Death Row Prisoner (p 51)
  50. Life-Sentenced California Prisoner Cannot be Convicted Under Both §§ 4500 and 4501 (p 51)
  51. California Attorney Disbarred for Deceiving 
Prisoners Seeking Resentencing (p 52)
  52. Qualified Immunity Denied for Iowa Prison Doctor’s MRI Delay 
for Non-Medical Reasons (p 52)
  53. HRDC Wins Consent Decree, $350,000 in Jail Censorship Suit 
against California’s Sonoma County (p 53)
  54. DOJ Inspects BOP Food Service Operations, 
Finds Troubling Issues at Multiple Facilities (p 54)
  55. Tennessee Legislature Passes Bill to Penalize Private Prisons 
for High Mortality Rates (p 55)
  56. Ninth Circuit: Continuing-Violations Doctrine Applies 
for PLRA Administrative Exhaustion Purposes (p 56)
  57. Nebraska Supreme Court Clarifies Award of Time Served 
Credit for Non-Citizen Awaiting Extradition (p 57)
  58. Third Circuit Upholds Award of $265,000 to Prisoner 
Who Was Sexually Assaulted Twice by the Same Guard (p 58)
  59. Shady Firm Awarded $78 Million Contract for Services 
at Florida’s “Alligator Alcatraz” (p 59)
  60. Guaranteed Basic Income Programs for Prisoners 
Reduce Food Insecurity and Homelessness (p 60)
  61. Trump’s “Big Beautiful Bill” Gave Massive Handouts to ICE and Private Prison Industry (p 60)
  62. Sixth Circuit Order Sealing Records 
in Private Prison Shareholder Suit 
Vacated, Remanded (p 61)
  63. News in Brief (p 62)
  64. Former Oregon Prison Guard Sergeant Sentenced 
for Sexually Abusing Imprisoned Women (p 62)

Now Under Federal Receivership, 
New York City’s Rikers Island Jails Still Have 
No Plan to Improve, No Firm Date to Close

With its sixth and seventh detainee deaths of the year coming just minutes apart on June 20, 2025, New York City’s Rikers Island jail complex eclipsed its death toll for all of 2024. Benjamin Kelly, 37, and James Maldonado, 56, were the latest of at least 40 people who have ...

From the Editor

 

After 35 years of publishing Prison Legal News, one thing that has become clear is that when it comes to the American criminal justice system, not all stories have an ending; some are fairly characterized as never-ending stories. We have reported on Rikers Island for our entire ...

Watchdog Calls Out D.C. for Dragging Feet 
on Construction of New Jail

A report issued by the Office of the D.C. Auditor (ODCA) on May 28, 2025, outlined the municipality’s “urgent need for a new jail.” The population of the existing lockup, spread over two adjacent buildings constructed between 1976 and 1992, soared to 1,945 in June 2024, from just 1,384 a ...

$75,000 for Transgender Maryland Prisoner Raped by Guard

On September 25, 2024, the Maryland Department of Public Safety and Correctional Services (DPSCS) agreed to pay $75,000 to a transgender state prisoner who accused a guard of raping her in December 2021 at Patuxent Institution, a treatment facility in Jessup.

As PLN reported, Leyleen Lillith Aquino, 39, filed suit ...

Texas Social Workers Challenge Blanket Denial of State Occupational License Based on Youthful Assault Convictions

The Institute of Justice (IJ) is helping two Texas women with master’s degrees in social work challenge a 2019 state law that bars anyone with a prior conviction involving the threat or use of force from ever receiving a license to practice in a healthcare profession, including social work. Each ...

CDCR Held in Contempt, Fined $112 Million 
in Longstanding Litigation Over Mental Health Care

Coleman v. Newsom, a class-action case challenging inadequate mental health care for California state prisoners, has been ongoing for the past 35 years. Over the course of that litigation, a bench trial was held where a federal district court “found overwhelming evidence of significant and chronic understaffing among ...

Two Exonerated Illinois Prisoners Win Settlements 
Totaling $14.5 Million

A pair of former Illinois prisoners, each exonerated after spending 23 years behind bars for crimes they did not commit, accepted a total of $14.5 million in settlements from the City of Rockford, which voted in April 2025 to issue bonds to cover the debt. 

Both Patrick Pursley, now 55, ...

California Prisoners Sue Gynecologist for Sexual Abuse

On February 2, 2025, a class-action complaint was filed by women housed at the California Institute for Women (CIW). The suit alleges that Dr. Scott Lee abused dozens of prisoners for at least seven years while he acted as the institutional gynecologist at the facility. It is also alleged that ...

$2.6 Million Paid for Detoxing Washington Jail Detainee Allowed 
to Leap to His Death, Additional NaphCare Payout Undisclosed

A young dad detoxing from fentanyl when he was booked into a Washington jail began exhibiting increasingly bizarre behavior, yet he was ignored until he climbed atop a metal sink and dived head-first onto the concrete floor, suffering a fatal spinal injury. That was the allegation made against staff at ...

Oklahoma Prisoner’s Execution Was Expedited 
by the Trump Administration

John Hanson, 61, received a three-drug lethal injection on the morning of June 12, 2025, and was pronounced dead by 10:11 a.m., reported USA TODAY. Hanson—who received a life sentence for carjacking, kidnapping, and killing Mary Bowles in Tulsa in 1999—had been locked up in a federal facility in ...

Multiple Prisoner Suits Accuse Guards of Violence 
at Virginia BOP Lockup

A group of cases pending in the U.S. District Court for the Western District of Virginia paint a picture of senseless violence and petty retaliation by officials with the federal Bureau of Prisons (BOP) at the U.S. Penitentiary-Lee near rural Pennington Gap. 

At this same prison in 2023, BOP prisoner ...

Sixth Circuit Holds Dismissal Not Automatic When Plaintiff Simultaneously Files Same Claims in State Court

The U.S. Court of Appeals for the Sixth Circuit reversed a district court’s dismissal of a plaintiff’s claim of retaliation, finding the district court misapplied a waiver doctrine that prevented persons from filing the same claim in state and federal courts.

Lionel Harris is a prisoner at the Madison Correctional ...

Alabama DOC Attorneys Reprimanded for 
Filing AI-Written Briefs in Prisoner’s Suit

The federal court for the Northern District of Alabama issued an order on May 16, 2025, demanding that attorneys representing the state Department of Corrections (DOC) show cause why they should not be sanctioned for filing error-riddled briefs apparently written by an artificial intelligence (AI) software program.

AI programs are ...

FCC Backtracks on 2024 Order to Cut 
Prison Phone and Video Rates by Half

On June 30, the Federal Communications Commission announced a two-year postponement of a rule to lower the price of phone and video calls in prisons and jails. As PLN reported, the FCC voted in 2024 to approve the regulation, which was set to go into effect nationwide later this year ...

Nebraska Considers Curbing Double-Bunking 
in Restrictive Housing

Since 2017, at least three prisoners in Nebraska have died of suspected homicides while locked in double-bunked cells. Nebraska, whose prison system routinely operates at 140% capacity, has paid nearly $900,000 in lawsuit settlements related to the deaths, the Flatwater Free Press reported. Now, the state legislature is considering a ...

$1.2 Million for New York Prisoner Waterboarded by Guards

On March 25, 2025, the federal court for the Northern District of New York granted dismissal to a suit filed by former state prisoner Matthew Raymond, after he accepted a $1.2 million settlement from the state Department of Corrections and Community Services (DOCCS) for an alleged violent assault by guards ...

Former Maine Prison Guard Arrested 
and Detained by ICE Agents

Gratien Milandou-Wamba, 32, fled to the United States on a tourist visa in 2023 from the Republic of the Congo; he applied for asylum several months later, claiming that he had been tortured in his home country because of his brother’s political activity. Milandou-Wamba then obtained a work permit and ...

$15 Million Settlement Reached in San Diego Jail Detainee’s Untreated Withdrawal Death

On September 13, 2024, nearly five years after a detainee died of untreated heroin withdrawal symptoms at San Diego County’s Las Colinas Detention Facility, a $15 million settlement agreement resolving a lawsuit brought by her estate was filed in the U.S. District Court for the Southern District of California. Under ...

$6.75 Million Settlement Reached in Suit Accusing 
Massachusetts Guards of Retaliatory Assaults on Prisoners

Under an agreement reached on May 21, 2025, Massachusetts will pay $6.75 million to settle claims by a group of some 150 current and former state prisoners who accused guards at Souza-Baronowski Correctional Center (SBCC) of carrying out a systematic campaign of retaliatory beatings, following a disturbance in early 2020 ...

Missouri Prison Nurse Sentenced 
to 12 Years for Poisoning Husband

On June 25, Amy Murray, a 46-year-old former prison nurse in Miller County, received a 12-year sentence after she entered an Alford plea—a guilty plea in which the defendant maintains innocence—around charges related to poisoning her husband, Joshua, and setting fire to their home. 

Seven years ago, in December 2018, ...

Fifth Circuit Greenlights Federal Takeover of Mississippi Jail

The U.S. Court of Appeals for the Fifth Circuit approved the appointment of a receiver to oversee operations of the Raymond Detention Center (RDC) in Hinds County, Mississippi. The district court’s action was a contempt sanction imposed for the County’s repeated failures to comply with a consent decree.

RDC has ...

$325,000 Paid to Former Wisconsin Prisoner Whose Cancer Biopsy Was Delayed by Previously Disciplined Doctor

On September 19, 2024, Wisconsin Assistant Attorney General Mary Kathlin Sickel put the final signature on an agreement paying $325,000 to former state prisoner Darnell Price, settling his claims that a state Department of Corrections (DOC) physician ignored a mass on his leg which later proved to be cancerous. By ...

Texas Lawmakers Restrict Bail and Raise Criminal Penalties, 
Punt on Prison and Jail Conditions

When the Texas legislature adjourned its annual session on June 2, 2025, lawmakers had taken some steps to restrict bail and successfully fought back an effort to expand parole. Most other jail and prison reforms—including a bill to air-condition the state’s miserably hot lockups—were left on the table, too. Meanwhile, ...

SCOTUS Partially Overturns Pavey, Holds PLRA Exhaustion 
Dispute Must Go to Jury Even If Intertwined with 
Merits of Michigan Prisoner’s Claim

Since the passage almost 30 years ago of the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, prisoners have been required prior to filing suit against their captors to exhaust all available administrative remedies, usually through the prison grievance system. A body of case law has since arisen defining the ...

PLN Publisher Wins Settlement Records from Centurion 
in Florida Prisoner’s Wrongful Death

On June 24, 2025, Florida’s Seventh Judicial Circuit Court for Putnam County ruled that Centurion of Florida, LLC was acting as the functional equivalent of a state agency when it contracted with the state Department of Corrections (DOC) to provide healthcare to prisoners; therefore, it was obligated under the state’s ...

Prison Gerrymandering 
Alive and Well in Oklahoma

As states across the country push to end “prison gerrymandering”—the U.S. Census practice of counting prisoners in the typically rural and white areas where they are held, thereby diluting the voting power of the urban and non-white areas that they come from—the non-profit Prison Policy Initiative (PPI) released a report ...

After Judge’s Letter, at Least 22 Former FCI Dublin Prisoners Granted Compassionate Release

In May 2024, California federal District Judge Yvonne Gonzalez Rogers took the unusual step of writing a letter to numerous other judges who had sentenced women formerly incarcerated at Federal Correctional Institution Dublin and might be considering compassionate release pursuant to 18 U.S.C. § 3582(c)(1)(A). In the letter, she described conditions ...

Ninth Circuit Revives Prisoner’s Claim Based on Guard’s 
Thwarting of Administrative Remedies

The U.S. Court of Appeals for the Ninth Circuit reversed the dismissal of a prisoner’s civil rights action for the failure to exhaust administrative remedies. The Court found the prisoner was “reliably informed” by a prison grievance coordinator that the remedy was “not available to him.”

The appeal was filed ...

$815,000 Settlement in Nevada Class-Action Suit 
Over Debit Release Cards

A Nevada federal district court has approved a $815,000 settlement in a class-action case challenging the use of fee-laden debit cards that prisoners receive upon release, containing the balance from their inmate trust accounts. The lawsuit, filed by former prisoner Christopher Watkins, named Rapid Financial Solutions, Inc. d/b/a Access Freedom ...

Review: “Reforming the Shadow Carceral State”

In an academic paper published in the November 2024 issue of Theoretical Criminology, researchers Brittany Friedman, Gabriela Kirk-Werner, and April D. Fernandes examined efforts to reform what they termed the “shadow carceral state.”

While the carceral state encompasses the criminal legal system—jails, prison, parole, etc.—the shadow version consists of ...

Fourth Circuit Revives Wrongful Conviction Claim of Exonerated Maryland Prisoner, State Pays Him $3.1 Million

On January 6, 2025, the U.S. Court of Appeals for the Fourth Circuit reinstated the claim of a now-exonerated Maryland prisoner against a trio of Baltimore cops who allegedly coerced a confession from an eyewitness that was used to convict him of a fatal shooting in December 1986. The false ...

HRDC Wins $480,000 in Legal Fees from Centurion for Denied New Mexico Records

On February 17, 2025, Paul Wright, Executive Director of the Human Rights Defense Center (HRDC), signed an agreement accepting a $480,000 payment to resolve claims for records made in a suit filed in state court against Centurion of New Mexico LLC, the contracted medical provider to the state Corrections Department ...

Costs of U.S. Incarceration to Families
Pegged at Nearly $350 Billion a Year

To maintain and operate the prisons and jails that hold nearly 2 million American costs a lot—an estimated $82 billion a year, as PLN reported. [See: PLN, Sep. 2023, p.56.] But that is just the direct cost to governments. What about the costs to prisoners and their families, for ...

DOJ Tables Controversial Kentucky Prison 
to Claw Back $500 Million Budget

Since 2006, U.S. Rep. Hal Rogers has worked to bring a new prison to a former strip-mining site in Eastern Kentucky. Although previous budget proposals turned down the project, Rogers was able to secure $500 million in federal funding for the medium-security prison in 2022. Around this time, the proposed ...

$3,800 Paid to Ohio Prisoner for Denied Records Request

In a letter dated July 8, 2024, Ohio Attorney General Dave Yost (R) confirmed a $2,800 settlement with state prisoner Trevor J. Teagarden, resolving claims for denied public records requests made to the state Department of Rehabilitation and Corrections (DRC) pursuant to ORC § 149.43. An additional $1,000 was added by ...

Delaware’s ACLU Files Action on Behalf Of Six Prisoners 
Assaulted During Midnight Raid

On behalf of six prisoners in Delaware, the ACLU filed a civil rights complaint against a Warden and his Correctional Emergency Response Team (CERT) for assaults and abuse that occurred during a midnight raid.

All of the plaintiffs were prisoners held at the James T. Vaughn Correctional Center in Smyrna, ...

DOJ Finds Unconstitutional Conditions in Texas Juvenile Detention

Texas lawmakers took steps in opposite directions toward solving a crisis in state juvenile detention centers, after all five lockups operated by the state Juvenile Justice Department (TJJD) were found to be violating the civil rights of youthful offenders by the federal Department of Justice (DOJ). In response, state Sen. ...

HRDC Collaborates on Prison Telecom Cost Report 
to Washington Lawmakers

A report on prison telecom costs presented to state lawmakers in Washington on December 13, 2024, showed dramatic decreases nationwide in the price of calls from prisons and jails over the past decade. A similar drop was not found in rates for e-messages sent from lockups. Data provided by the ...

Over Eight Years in Prison for iCare Founder Who Ran Prisoner Gift Basket Scam

Robert Rahrle, who took millions of dollars online selling gift baskets for prisoners that were never delivered, was sentenced to a 100-month federal prison term for wire fraud and tax evasion on June 2, 2025. The federal court for the Northern District of New York also ordered him to serve ...

Suit Filed Over Fatal Beating of New York Prisoner 
That Sparked Massive Guard Strike

A federal civil rights complaint filed on January 15, 2025, accused the New York Department of Corrections and Community Services (DOCCS) and over a dozen of its officials of violating the Eighth Amendment rights of prisoner Robert Brooks with use of excessive force and deliberate indifference to his resulting serious ...

Life Sentences, by the Numbers

According to a report by The Sentencing Project published in January 2025, almost 200,000 prisoners in the United States are serving life sentences. The report—the non-profit organization’s sixth national census on this issue—included data related to sentences of life with parole, life without parole (LWOP), and “virtual” or de-facto life ...

Sixth Circuit Upholds $45 Million Verdict for 
Wrongfully Convicted Former Ohio Prisoner

A $45 million wrongful conviction award to an exonerated Ohio prisoner was upheld by the U.S. Court of Appeals for the Sixth Circuit on May 2, 2025. Miami Township and its Police Department (MTPD) had challenged the verdict, claiming that Det. Matthew Moore acted in bad faith and outside the ...

Former California Prison Guard 
Pleads Guilty to Planting Contraband 
He Pretended to Discover

Avelino Ramirez, 52, worked at the San Quentin State Prison from 2013 to 2022, according to his plea agreement. In 2022, he was promoted to K-9 sergeant and transferred to the California Medical Facility in Vacaville. Ramirez, between October 2021 and February 2024, orchestrated a scheme to plant contraband in ...

Tenth Circuit Ruling Paves Way for $2.7 Million Settlement 
for Intellectually Disabled Jail Detainee Raped by Sheriff

In a settlement reached on December 20, 2024, Colorado’s Sedgwick County agreed to pay $2.7 million to Peatinna Biggs, an intellectually disabled former detainee in the county jail who was raped by the Sheriff during transport. The County initially beat back claims for any liability in the U.S. District Court ...

SCOTUS Clamps Down on Bivens Extension to Prisoner 
Beaten by BOP Guards at Virginia Lockup

On June 30, 2025, a federal prisoner lost his last chance at recovering damages for injuries suffered when he was repeatedly shackled and beaten by guards at the U.S. Penitentiary (USP)—Lee in Petersburg, Virginia. That’s when the Supreme Court of the U.S. (SCOTUS) overturned an appellate court’s decision allowing Andrew ...

Ninth Circuit Agrees That Former Guantanamo Detainee 
Lacks Grounds to Sue for Waterboarding

On June 30, 2025, the U.S. Court of Appeals for the Ninth Circuit affirmed dismissal of a complaint filed by Abu Zubaydah, 52, a falsely accused Al-Qaeda conspirator captured after the terrorist attacks on September 11, 2001, who is still being held without charges as an “enemy combatant” by the ...

$1.875 Million Partial Settlement for Colorado Detainee’s 
Death from Untreated Alcohol Withdrawal; 
Claims Against Wellpath Pending Bankruptcy

On November 19, 2024, the Board of County Commissioners of Colorado’s El Paso County approved an agreement with the Estate of Daniel James Murray, a detainee who died at the county jail of untreated alcohol withdrawal in July 2022. Surviving claims against the jail’s contracted medical provider, Wellpath LLC, remain ...

$95,000 Paid to Nevada Prisoner Denied 
Muslim Prayer; Pending Cases Allege Continued 
Discrimination Against Non-Protestants

On December 6, 2024, two Nevada prisoners filed notices as interested parties in the religious discrimination case of a third, Said Elmajzoub. By that point, he had won a $95,000 settlement from the state Department of Corrections (DOC), resolving his claims its officials unreasonably refused to accommodate his request for ...

On Remand, Eleventh Circuit Clarifies, Affirms Grant 
of Habeas Relief to Death Row Prisoner

Joseph Clifton Smith beat Durk Van Dam to death during a robbery, and was sentenced to death following his conviction in 1997. He has been appealing his case for almost three decades, most recently resulting in a ruling by the U.S. Supreme Court and remand to the Eleventh Circuit Court ...

Life-Sentenced California Prisoner Cannot be Convicted Under Both §§ 4500 and 4501

While serving a life sentence, Richard Manuel Nava stabbed a fellow California state prisoner multiple times with a sharpened piece of metal. He was charged under Pen. Code § 4502(a) for possessing a weapon in a penal facility; under § 4500 for assault with a deadly weapon and with malice aforethought while ...

California Attorney Disbarred for Deceiving 
Prisoners Seeking Resentencing

Los Angeles attorney Aaron Spolin pleaded no contest to misconduct on June 17, 2025, agreeing to be stripped of his law license because he “promoted false hopes in his clients and their families that the clients’ sentences would be reduced when in fact that was highly unlikely.”

As PLN reported, ...

Qualified Immunity Denied for Iowa Prison Doctor’s MRI Delay 
for Non-Medical Reasons

The U.S. Court of Appeals for the Eighth Circuit affirmed the denial of qualified immunity to a prison doctor who delayed the scheduling of a prisoner’s MRI due to the prisoner’s upcoming parole hearing and the possibility of a grant of parole.

Iowa prisoner Travis Dantzler sued Dr. Tonia Baldwin, ...

HRDC Wins Consent Decree, $350,000 in Jail Censorship Suit 
against California’s Sonoma County

On June 2, 2025, the federal court for the Northern District of California issued a consent decree settling demands for injunctive relief filed by the Human Rights Defense Center (HRDC) against California’s Sonoma County over censorship of publications at the Main Adult Detention Facility (MADF) in Santa Rosa. In addition ...

DOJ Inspects BOP Food Service Operations, 
Finds Troubling Issues at Multiple Facilities

In the first week of June 2024, the Department of Justice’s Office of the Inspector General (OIG) conducted surprise inspection at six Bureau of Prisons (BOP) Food Service Departments, finding deficiencies at the facilities which “impair[ed] the administration of food service.”

The inspections occurred nearly simultaneously at one prison in ...

Tennessee Legislature Passes Bill to Penalize Private Prisons 
for High Mortality Rates

In April 2025, the Tennessee General Assembly passed SB 1115, legislation that imposes penalties on privately-operated prisons if they have death rates twice as high as the rate at an “equivalent state-operated facility.” The bill was signed into law by Governor Bill Lee (R) on May 9, 2025.

The only ...

Ninth Circuit: Continuing-Violations Doctrine Applies 
for PLRA Administrative Exhaustion Purposes

On December 31, 2024, the U.S. Court of Appeals for the Ninth Circuit held that a prisoner “need not file repeated grievances if the (prisoner) has identified one continuing harm or a single course of conduct [of] which later events are a part.” In other words, the Court adopted the ...

Nebraska Supreme Court Clarifies Award of Time Served 
Credit for Non-Citizen Awaiting Extradition

On December 6, 2024, the Supreme Court of Nebraska clarified when a sentencing court is required to award credit for time served while incarcerated in a foreign country awaiting extradition. It held that crediting time served was mandatory provided the time was for the instant charge and had not been ...

Third Circuit Upholds Award of $265,000 to Prisoner 
Who Was Sexually Assaulted Twice by the Same Guard

The U.S. Court of Appeals for the Third Circuit upheld a jury’s award of $265,000 to Pennsylvania prisoner Henry Unseld Washington who was sexually assaulted twice by guard T.S. Oswald.

In 2013, Oswald and another guard identified as a “sergeant” escorted the handcuffed Washington to the visiting room. Oswald and ...

Shady Firm Awarded $78 Million Contract for Services 
at Florida’s “Alligator Alcatraz”

An obscure consulting firm in Jacksonville, Florida was awarded a $78 million contract in early July 2025 to provide a range of critical services at a hastily built immigrant detention center in the Everglades, dubbed by state officials as “Alligator Alcatraz.” The firm, Critical Response Strategies LLC (CRS), employed staffers ...

Guaranteed Basic Income Programs for Prisoners 
Reduce Food Insecurity and Homelessness

The cities of Gainesville, Florida, and Durham, North Carolina, experimented with providing guaranteed basic income (GBI) to prisoners who were reentering the community, and have released information about the outcomes created by the program.

Both programs enrolled just over one hundred former prisoners. The Gainesville cohort received $1,000 upon release, ...

Trump’s “Big Beautiful Bill” Gave Massive Handouts to ICE and Private Prison Industry

On July 4, 2025,President Donald Trump (R) signed into law a budget reconciliation bill (H.R. 1) that drastically increased funding for immigration enforcement and policing. Originally titled the “One Big Beautiful Bill Act,” the megabill awarded a whopping $170 billion over the next decade to bolster an already sprawling border ...

Sixth Circuit Order Sealing Records 
in Private Prison Shareholder Suit 
Vacated, Remanded

As of 2016, CoreCivic—formerly Corrections Corp. of America—contracted with the federal Bureau of Prisons (BOP) to operate five facilities. In August of that year, a report by the Inspector General for the Dept. of Justice found the company’s prisons “had more inmate violence (by 35%), inmate-on-inmate assaults (by 64%), sexual ...

News in Brief

Alabama: On Sunday, June 15, 2025, state Department of Corrections (DOC) guard Airika Dorsey was arrested for allegedly smuggling food to a prisoner at St. Clair Correctional Facility, according to WABM in Birmingham. The DOC confirmed that Dorsey was caught in the act and subsequently booked into the St. Clair ...

Former Oregon Prison Guard Sergeant Sentenced 
for Sexually Abusing Imprisoned Women

As PLN has extensively reported, the Coffee Creek Correctional Facility (CCCF), Oregon’s only women’s prison, has been a decades long hotbed of staff sexual abuse. Oregon Department of Corrections (DOC) administrators have long known about the problem, which has been detailed in reports by independent groups, but have done little ...