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Brief • 2003
governmental interest put forward to justify it;” (2) whether there are alternative means of exercising the right that remain open to prison inmates; (3) what effect accommodation of the interest would have ...
Brief • January 12, 2015
knowledge of the symptoms that accompany DTs and alcohol withdrawal. 57. Defendants Giordano, Lambert, and Hyde all went to Mr. Moffitt’s cell “to see what was going on” with him. When Defendants Giordano ...
Brief • September 11, 2017
under CDOC’s Standards. 41. Additionally, to be “considered” for DAA medication treatment, the prior Standards required that a prisoner must demonstrate what CDOC regarded as “an absence of high-risk ...
testified that he did not see the attacker in the courtroom. Exh. B at 82. When directed to look at Mr. Jones, Miller testified: “he don’t look nothing like -- if that is him, it don’t look like what he ...
Complaint does not allege how any Defendant personally had control over staffing levels at HCCC. In fact, the Amended Complaint does not even allege what each Defendant’s specific duties were. Without some ...
Brief • May 22, 2015
to Leonard and walked 25 toward the house. Annalesa saw Fredrick and told the officers what he was doing. 26 27 4.33 As Fredrick went into his back yard, SWAT officers interceded. Fredrick tried ...
Sergeant Woody Little about what he observed and "let him make the decision about how the jail wanted to proceed." Despite returning to the medical unit at 8:55pm and hearing Mr. Myers had calmed down ...
meals due to personal health concerns. 47. On or about April 7, 2014, and while housed in West Valley 5 Detention Center, Plaintiff discovered shards of glass and what appeared to be 6 human feces ...
Brief • August 24, 2017
will be able to call in to report 6 what they reasonably believe to be discrimination. The hotline 7 moderators will not disclose the name of any reporting employee to 8 GEO management, unless necessary ...
Brief • June 7, 2018
his 6 girlfriend’s deportation. “You’re the one from the newspaper,” the ICE agent 7 who detained him reportedly said. “My supervisor asked me to come find 8 you because of what appeared ...
to engage in abuse because they believe they will rarely be held accountable, administratively or criminally. Few people outside the prison walls know what is going on or care if they do know. Fewer still do ...
defense, based on a “clearly established law” standard that was unheard of before the late twentieth century. In short, the doctrine has become exactly what the Court assiduously sought to avoid ...
Brief • December 13, 2017
by LAPD, was motivated by retaliatory animus. (Manning Second Supp. Decl. ¶¶ 2-11.) Although Wilson contests some of Manning’s representations, it is unclear to what 6 extent he leaves other parts ...
Brief • December 28, 2016
to be present at all stages of the prosecution of a criminal case, the news media plays a critically important role in ensuring that the public is informed about what has transpired from an arrest to sentencing ...
Brief • 2009
and placement of a central line for IV and IV pressors. Pt placed on broad spectrum antibiotics and subsequently transferred to Kadlec Medical Center ICU. Conservative treatment is not what a patient needs when ...
Brief • 1998
is required include the context in which the communication is taking place, the number of people involved, and the importance of the communication. In determining what type of auxiliary aid and service ...
Brief • 2006
operating procedures which governed the decision to turn off the water to a detainee’s cell, including who could make such a decision, who was notified, what records would be kept, how long the water could ...
Brief • 2001
of the nature of what was being done. 60. Defendants breached their duties by acting intentionally, maliciously, with deliberate indifference and/or negligently in facilitating the escape of Martinez ...
Brief • 2013
is exactly what was done and of which evidence remains in inmate’s chart.” ! Ms. Steadman’s response to Mr. Mitchell’s grievance is demonstrably false. Dr. Limbird writes in his notes dated 8/26/2010 ...
Brief • 1999
does not tax receipt of the funds. The State is wrong. The operative statutory language indicates that is precisely what the statute does: 24 25 When an inmate receives any funds in addition to his ...
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