Georgia Advocacy Office v. Theodore Jackson

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USCA11 Case: 19-14227 Date Filed: 07/14/2021 Page: 1 of 40 [PUBLISH] IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT ________________________ No. 19-14227 ________________________ D.C. Docket No. 1:19-cv-01634-WMR-RDC GEORGIA ADVOCACY OFFICE, M.J., K.H., on behalf of themselves and others similarly situated, Plaintiffs – Appellees, versus THEODORE JACKSON, in his official capacity as Sheriff of Fulton County, MARK ADGER, in his official capacity as Chief Jailer, MEREDIETH LIGHTBOURNE, in her official capacity as Medical Director, TYNA TAYLOR, in her official capacity as Detention Captain, PEARLIE YOUNG, in her official capacity as Detention Lieutenant, Defendants – Appellants. USCA11 Case: 19-14227 Date Filed: 07/14/2021 Page: 2 of 40 ________________________ Appeal from the United States District Court for the Northern District of Georgia ________________________ (July 14, 2021) Before WILSON, GRANT, and TJOFLAT, Circuit Judges. TJOFLAT, Circuit Judge: The District Court below entered a preliminary injunction requiring Fulton County Jail officials to provide regular out-of-cell time to female inmates with psychiatric disabilities and to improve the sanitary conditions in their cells. The officials appealed. We consider whether the preliminary injunction expired by operation of law under the terms of the Prison Litigation Reform Act (“PLRA”). We hold that it has, and accordingly dismiss this appeal as moot and vacate the preliminary injunction order. I. The Plaintiffs in this action are the Georgia Advocacy Office, a nonprofit dedicated to serving disabled Georgia residents, and two psychiatrically disabled female inmates of the Fulton County Jail (“the Jail”). On April 10, 2019, Plaintiffs filed a class action for injunctive relief in the United States District Court for the Northern District of Georgia on behalf of “all women with psychiatric disabilities 2 USCA11 Case: 19-14227 Date Filed: 07/14/2021 Page: 3 of 40 who are now or will in the future be confined in the Fulton County Jail system.” 1 The Defendants named in the complaint were Theodore Jackson, Sherriff of Fulton County; Mark Adger, Chief Jailer for the Sherriff’s Office; Meredieth Lightbourne, Medical Director for the Sherriff’s Office; Tyna Taylor, Detention Captain for the South Fulton Municipal Regional Jail; and Pearlie Young, Detention Lieutenant for the South Fulton Municipal Regional Jail. Plaintiffs alleged the conditions at the Jail violate the Eighth Amendment’s ban on “cruel and unusual punishments” and the Fourteenth Amendment’s equal protection clause. They also alleged violations of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12101 et seq., and the Rehabilitation Act of 1973, 29 U.S.C. § 701 et seq. Plaintiffs based their claims mainly on the Jail’s alleged practice of confining psychiatrically disabled female inmates to isolation cells (called “mental health pods”) for months at a time as well as the unsanitary conditions in those cells. Their equal protection claim arose from the Jail’s alleged policy of barring female inmates from receiving jail-based competency restoration services.2 1 Plaintiffs also seek relief on behalf of a subclass including “all women with psychiatric disabilities who are now or will in the future be deemed incompetent to stand trial while confined in the …

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