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March 11, 2021

Second Circuit panel finds all sorts of constitutional problems with Connecticut's conditions of confinement for former death row inmate

A helpful reader altered me to a notable quirky Second Circuit panel ruling today on prison conditions in Reynolds v. Quiros, No. 19-2858-pr (2d Cir. Mar. 11, 2021) (available here). The case is quirky because it arises from Connecticut's decision to create special statutory conditions of imprisonment when it repealed its death penalty.  The ruling is notable because the defendant, a former member of death row, has succeeded on a number of challenges to these conditions in his federal litigation, and now the Second Circuit panel comes to "hold as follows:

(1) The District Court erred by deciding disputed issues of material fact in granting summary judgment in favor of Reynolds on his claims under the Eighth Amendment, and the Due Process Clause of the Fourteenth Amendment;

(2) The District Court correctly concluded that, with respect to Reynolds, Conn. Gen. Stat. § 18-10b is an unconstitutional bill of attainder; and

(3) Reynolds’ unreviewable classification score of Risk Level 5 violates his rights under the Equal Protection Clause of the Fourteenth Amendment because the difference in his treatment compared to that of other similarly-situated inmates lacks a rational basis."

March 11, 2021 at 05:18 PM | Permalink


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