Sign Up

NCLA Site Search

Cases

Martinez-Brooks v. Garland

CASE SUMMARY

Did we achieve our litigation objective? Yes. Dianthe Martinez-Brooks was allowed to continue her rehabilitation in home confinement, instead of being forced to go back to prison, in contravention of the CARES Act.

Court Outcome: Case dismissed after Attorney General Merrick Garland acknowledged NCLA’s argument and changed the Bureau of Prisons policy.

Larger Impact: NCLA’s argument in this case was so irrefutable that when Merrick Garland was made aware of the issue, he publicly agreed with NCLA during questioning in a Congressional hearing, at which point the government had no choice but to change its policy. Thousands of prisoners were allowed to continue their rehabilitation under the CARES Act, because NCLA forced COP to follow the statue Congress passed.

Summary: NCLA sought to obtain declaratory relief and to halt DOJ’s effort to disregard prior court decisions on prison alternatives for nonviolent and medically vulnerable people.

NCLA represented Dianthe Martinez-Brooks, a 52-year-old nonviolent first-time offender then serving a federal prison term on home confinement. BOP released her from prison after determining that she posed no threat to the public but was at serious risk of severe illness or death should she contract Covid-19 in prison—in accordance with Attorney General William Barr’s “home confinement” memorandum.

According to statute, BOP must always evaluate use of home confinement as “pre-release custody” for those inmates in the last six months of their sentence. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) passed by Congress in March 2020 directed BOP to use home confinement for medically vulnerable people. Neither the relevant statute nor the CARES Act’s applicable section deprived BOP of its discretion to make an initial placement outside of a prison setting. Likewise, neither the relevant statute nor the CARES Act required BOP to revoke home confinement for medically vulnerable people after six months.

Nevertheless, in January 2021, BOP’s General Counsel directed the agency to order the return of more than 4,000 inmates once the declared Covid-19 emergency ended, regardless of the nature of their offenses or their conduct while on home confinement. NCLA believed the agency had wrongly interpreted an obligation to release people to home confinement near the end of their sentences as a limit on how long anyone could be released to home confinement, no matter why they were released initially.

This interpretation contradicted several federal court decisions, including one from the Third Circuit, the pertinent jurisdiction in this case, which held that this statute did not preclude having a defendant serve a much longer portion of her term on home confinement. To the contrary, the Third Circuit specifically stated that BOP was obligated to evaluate each individual’s circumstances and make a determination as to where she should serve the entirety of her sentence.

NCLA argued that the statute vested BOP with sufficient discretion to allow Ms. Martinez-Brooks to serve the remainder of her sentence on home confinement.

OUR CLIENT

Dianthe Martinez-Brooks, Plaintiff

OUR TEAM

Kara Rollins
Litigation Counsel
Jenin Younes
Litigation Counsel

RELEVANT MATERIALS

NCLA FILINGS

Memorandum Opinion for the Attorney General

December 21, 2021 | Read More

Plaintiff’s Sur-Reply in Opposition to Defendants’ Motion to Dismiss

November 12, 2021 | Read More

Defendants Reply Brief in Support of Their Motion to Dismiss Pursuant to Fed R. Civ. P. 12(b)(1)

November 8, 2021 | Read More

Plaintiff’s Response in Opposition to Defendants’ Motion to Dismiss

October 25, 2021 | Read More

Defendants Brief in Support of Their Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(1)

September 7, 2021 | Read More

SEE 6 FILINGS
PRESS RELEASES

In Reversal After NCLA Suit, DOJ to Allow Prisoners Moved to Home Confinement for Covid to Stay

December 22, 2021 | Read More

NCLA Refutes BOP’s Attempt to Dismiss Home Confinement Lawsuit for Medically Vulnerable Inmate

October 26, 2021 | Read More

NCLA Tells Court Bureau of Prisons May Keep Inmates on Home Confinement Post-Covid

May 18, 2021 | Read More

CASE HIGHLIGHTS

RELATED CASES
  • American Honda Motor Co., Inc. v. Walther, Dir., and Arkansas Department of Finance and Administration

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Due Process Violations

    The due process of law guarantees a right to be held to account only through the processes of an impartial court—something administrative tribunals violate every day.

    Case Closed -

    Agencies: Arkansas Department of Finance and Administration

    View Case
  • American Hospital Association, et al. v. Xavier Becerra, et al.

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Due Process Violations

    The due process of law guarantees a right to be held to account only through the processes of an impartial court—something administrative tribunals violate every day.

    Scope of Authority / Nondelegation

    The structure of the Constitution allows only Congress to legislate, only the Executive to enforce laws, and only the Judiciary to decide cases. But the Administrative State evades the Constitution’s avenues of governance when executive agencies issue regulations without statutory authorization from Congress.

    Case Closed - June 15, 2022

    Agencies: Department of Health and Human Services

    View Case
  • Aposhian v. Garland

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Scope of Authority / Nondelegation

    The structure of the Constitution allows only Congress to legislate, only the Executive to enforce laws, and only the Judiciary to decide cases. But the Administrative State evades the Constitution’s avenues of governance when executive agencies issue regulations without statutory authorization from Congress.

    Guidance Abuse

    Agency guidance is easier to promulgate than formal rules and regulations, so agencies prefer to issue it. Such “guidance” supplies relatively informal indications of how an agency interprets rules and statutes. Although guidance is not permitted to bind Americans (unlike laws made by elected legislators), agencies treat guidance as binding and courts often fail to stop them.

    Case Active - January 7, 2019

    Agencies: Bureau of Alcohol, Tobacco, and Firearms

    View Case
  • Howard and Karen Baldwin v. United States

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Case Closed - February 24, 2020

    Agencies: Internal Revenue Service

    View Case
  • Marcus Broadway v. United States

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Case Closed -

    Agencies: U.S. Sentencing Commission

    View Case
  • Thomas H. Buffington v. Denis McDonough, Secretary of Veterans Affairs

    Judicial Deference

    Deference doctrines require judges to defer to an administrative agency’s fact finding, or its interpretation of statutes and regulations. Thus, judges surrender their independent judgment and, where the government is a party, must exhibit systematic bias in the government’s favor, which denies due process of law to the other litigant.

    Due Process Violations

    The due process of law guarantees a right to be held to account only through the processes of an impartial court—something administrative tribunals violate every day.

    Case Closed -

    Agencies: Department of Veterans Affairs

    View Case

SHARE THIS CASE

Enter your email address above to be notified whenever we post a new document to this case.