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1 United States District Court for the Southern District of Mississippi Northern Division Brittany Waddell, Roger Ewing, Tony Sm

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1 United States District Court for the Southern District of Mississippi Northern Division Brittany Waddell, Roger Ewing, Tony Sm Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 1 of 6 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI NORTHERN DIVISION BRITTANY WADDELL, ROGER EWING, TONY SMITH, DANIEL HATTEN, DOUGLASS TRIPLETT, ERIK LEWIS, BOB HENDERSON, THOMAS HOLDER, and JAMARCUS DAVIS, individually and on behalf of a class of all others similarly situated, Civil Action No. 3:20-cv-340-TSL-RHW Plaintiffs, v. TOMMY TAYLOR, in his official capacity as Interim Commissioner of the Mississippi ORAL ARGUMENT REQUESTED Department of Corrections; RON KING, in his official capacity as Superintendent of Central Mississippi Correctional Facility; and JOE ERRINGTON, in his official capacity as Superintendent of South Mississippi Correctional Institution, Defendants. PLAINTIFFS’ MOTION FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION 1 Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 2 of 6 1. Plaintiffs respectfully request that the Court enter a temporary restraining order and preliminary injunction requiring the Defendants to effectively implement COVID-19 prevention and management protocols consistent with established standards of care for infection control and CDC guidelines. Pursuant to Local Rule 7(b)(6)(A), Plaintiffs respectfully request oral argument on this motion. 2. The Plaintiffs, who have brought this action on behalf of themselves and others similarly situated, are Brittany Waddell, Roger Ewing, Tony Smith, Daniel Hatten, Douglass Triplett, Erik Lewis, Bob Henderson, Thomas Holder, and Jamarcus Davis. They are residents of Mississippi’s two largest prisons, Central Mississippi Correctional Facility (CMCF) and South Mississippi Correctional Institution (SMCI), home to nearly 6,000 residents, combined.1 3. The Plaintiffs have brought this action under federal disability and constitutional law challenging MDOC’s inadequate response to the COVID-19 pandemic. In violation of the Eighth Amendment of the Constitution, MDOC is aware of the high risk of serious harm its failures entail and has knowingly created a substantial risk of preventable illness, hospitalization, and death to residents, as well as facility staff and members of surrounding communities. In violation of federal disability law, MDOC has failed to make reasonable modifications to their procedures to protect individuals who suffer from disabilities that make it more likely they will succumb to rapid disease progression and death due to COVID-19 infection.2 1 DeFendants are the Interim Commissioner of the Mississippi Department of Corrections (MDOC) and Superintendents of CMCF and SMCI (collectively Defendants or MDOC). 2 See Title II oF the Americans with Disabilities Act (ADA), 42 U.S.C. § 12132 (prohibiting public entities From discriminating against qualiFied persons with disabilities in providing services); Section 504 of the Rehabilitation Act (RA), 29 U.S.C. § 794(a) (prohibiting recipients of Federal Funds From discriminating against qualiFied persons with disabilities). These laws reQuire MDOC to make reasonable modiFications to their policies, practices, and procedures to prevent unnecessary harm to qualified individuals with disabilities whose disabilities place them at substantially increased risk of serious illness and death due to COVID-19 infection. 2 Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 3 of 6 4. The Plaintiffs therefore move for a temporary restraining order and a preliminary injunction requiring the Defendants to implement at CMCF and SMCI measures required by law to prevent irreparable harm to Plaintiffs, including but not limited to the following: a. Implement a facility-wide protocol, and effectively train residents and staff to use it, whereby a resident with coronavirus symptoms can report their symptoms and be evaluated by medical staff promptly; this method must work even if there is no security staff present on a zone or in the tower; sick call requests should result in a medical assessment as soon as possible but never longer than twenty-four hours after the resident’s first attempt to initiate the sick call process; b. Conduct immediate testing for anyone displaying known symptoms of COVID-19; c. Identify high-risk patients using CDC criteria, offer them testing for COVID-19, and provide them the option of being placed into housing areas with increased levels of infection control and twice daily symptom and sign checks; d. Institute an active surveillance program to screen every inmate for signs and symptoms of COVID-19 on a daily basis; e. Inform all incarcerated people of the waiver of all medical co-pays for individuals experiencing possible COVID-19 symptoms; f. Implement daily temperature checks in housing units where COVID-19 cases have been identified; g. Implement intensified cleaning and disinfecting procedures and ensure that, several times per day, cleaning and disinfecting occurs of surfaces and objects that are frequently touched, especially in common areas; h. Ensure that each incarcerated individual receives a free and adequate personal supply of: hand soap that does not cause skin irritation and which is sufficient to permit frequent hand washing, paper towels, facial tissues, cleaning implements such as sponges or brushes, and disinfectant products that are effective against COVID-19; also provide no-touch trash receptacles for disposal of paper products; i. Implement a facility-wide protocol, and effectively train residents and staff to use it, whereby a resident who runs out of soap can obtain more promptly; 3 Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 4 of 6 j. Provide incarcerated individuals with sufficient and effective cleaning supplies free of charge so that they may clean frequently touched items, such as phones, before use; k. Ensure that all individuals have access to hand sanitizer containing at least 60% alcohol; l. Require that all CMCF and SMCI staff wear PPE consistent with the CDC Guidance, including masks and gloves, when interacting with visitors and incarcerated individuals or when touching surfaces in common areas; do not disallow residents from using PPE and educate residents on its effective use; m. Ensure incarcerated people are provided guidance on how to protect themselves from COVID-19 and reduce COVID-19 transmission; provide such guidance in English and in the primary language of others housed in MDOC, including Spanish; n. Provide frequent communication to all incarcerated individuals regarding COVID-19, measures taken to reduce the risk of infection, best practices for incarcerated people to avoid infection, and any changes in policies or practices; o. Provide an anonymous mechanism for incarcerated individuals to report staff who violate these guidelines so that appropriate corrective action may be taken; p. Inform incarcerated people that they will not be retaliated against for reporting COVID- 19 symptoms or for reporting lack of compliance with COVID-19 mitigation measures; q. Ensure that incarcerated individuals can remain six feet apart to practice social distancing in compliance with CDC Guidance; r. Appoint an independent monitor with medical expertise to ensure compliance with these conditions, and provide the monitor with unfettered access to staff and to policies, procedures, and documents created to implement COVID-19 response procedures, as well as the ability to enter facility medical and housing units and have confidential communication with, and obtain video surveillance of, residents at any location in which they are being held; s. Provide Plaintiffs’ counsel with unfettered access to the same documents, places, and people, minus staff. In support of this motion, the Plaintiffs submit the exhibits listed below and are filing separately a memorandum setting forth the reasons why it should be granted. 4 Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 5 of 6 Exhibit 1: Expert Report of Gregg Gonsalves (May 14, 2020) Exhibit 2: Expert Report of Homer Venters (May 24, 2020) Exhibit 3: Declaration of Jamarcus Davis (May 6, 2020) Exhibit 4: Declaration of Roger Ewing (May 6, 2020) Exhibit 5: Declaration of Daniel Hatten (April 30, 2020) Exhibit 6: Declaration of Bob Henderson (May 6, 2020) Exhibit 7: Declaration of Thomas Holder (May 8, 2020) Exhibit 8: Declaration of Oziel Guzman (May 8, 2020) Exhibit 9: Declaration of Derrick Guyton (May 11, 2020) Exhibit 10: Declaration of Erik Lewis (May 7, 2020) Exhibit 11: Declaration of Douglass Triplett (May 12, 2020) Exhibit 12: Declaration Brent Ryan (May 8, 2020) Exhibit 13: Declaration of Tony Smith (May 6, 2020) Exhibit 14: Declaration of Brittany Waddell (May 13, 2020) Exhibit 15: COVID-19 Questions and Answers, MDOC (May 21, 2020) 5 Case 3:20-cv-00340-TSL-RHW Document 6 Filed 05/25/20 Page 6 of 6 Dated: May 25, 2020 /s/ Paloma Wu Jonathan L. Abram (pro hac vice forthcoming) Paloma Wu (Miss. Bar No. 105464) John P. Hamilton (pro hac vice forthcoming) Robert B. McDuff (Miss. Bar No. 2532) HOGAN LOVELLS US LLP MISSISSIPPI CENTER FOR JUSTICE Columbia Square, 555 Thirteenth Street, NW 5 Old River Pl., Ste 203 Washington, District of Columbia, 20004 Jackson, MS 39202 (202) 637-5600 (601) 709-0857 [email protected] [email protected] [email protected] [email protected] Madeleine R. Bech (pro hac vice forthcoming) Mark Whitburn (pro hac vice forthcoming) HOGAN LOVELLS US LLP WHITBURN & PEVSNER, PLLC 3 Embarcadero Center, Suite 1500 2000 E. Lamar Blvd., Suite 600 San Francisco, California 94111 Arlington, TX 76016 (415)
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