Georgia: Court Certifies Class Action for Prisoners Held Beyond Their Release Date
by Derek Gilna
A U.S. District Court judge in Georgia has certified a class-action suit that seeks to hold the Fulton County Jail liable for failing to release dozens of prisoners after they posted bond or were otherwise eligible for release.
According to Judge Michael L. Brown in his November 15, 2018 order, “The named Plaintiffs and the class Plaintiffs were overdetained at the Fulton County Jail – held beyond the time at which the basis for their detention had expired – when the Georgia Crime Information Center (GCIC) system became inoperable, preventing jail employees from running routine checks for warrants, holds, and detainers before releasing the inmates.
“Defendants held the inmates until the GCIC system could be accessed, overdetaining inmates for several days,” the judge added. “These overdetentions occurred without justification, in violation of Defendants’ ministerial duties to release the inmates once the bases for their detentions had expired, and with deliberate indifference to the constitutional rights of the inmates.”
The GCIC system was prone to outages, which resulted in prisoners being held too long, and the jail appeared either unwilling or unable to institute a viable alternative. The case was originally filed in the Superior Court of Fulton County before being removed to federal court.
“Based on Plaintiffs’ rigorous efforts thus far and a review of the undisputed evidence,” Judge Brown continued, “the Court is satisfied that members of the proposed class can be identified by reference to objective criteria and an administratively feasible process. In other words, the proposed class is ‘adequately defined and clearly ascertainable.’”
To be certified as a class action, a complaint must fulfill not only ascertainability but also three other conditions: numerosity, commonality of claims and the ability of class representatives to properly represent the class. The district court held, over the defendants’ objections, that all four requirements had been satisfied.
The parties agreed that the proposed class had at least 256 members, and that minor factual discrepancies in each proposed member’s claim would not prevent class certification. The defendants vigorously opposed the rest of the criteria for class certification but the court was not persuaded.
“Defendants, however, ignore Plaintiffs’ core allegation that Defendants refused to release them – not because of the administrative process – but because they adopted a policy of deliberately detaining people eligible for release during GCIC outages,” Judge Brown wrote. “A jail supervisor may not knowingly detain someone past the point at which he or she knows the person is eligible for release. The liability ... turns on whether they adopted an unconstitutional policy that caused the overdetention, not administrative delays.”
Besides, the district court concluded, “The class members’ claims here likely involve relatively small damages amounts. And it is unlikely that class members would pursue these claims on their own. The Court thus finds that the class action mechanism provides the most efficient method of resolving Plaintiffs’ claims here.”
The case remains pending on the defendants’ motion for summary judgment. See: Thompson v. Jackson, U.S.D.C. (N.D. Ga.), Case No. 1:16-cv-04217-MLB.
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Related legal case
Thompson v. Jackson
| Year | 2018 |
|---|---|
| Cite | U.S.D.C. (N.D. Ga.), Case No. 1:16-cv-04217-MLB |
| Level | District Court |