Order Regarding Treatment of People with Disabilities at SATF

Court Expert’s Addendum to Second Report Regarding Treatment of People with Disabilities at SATF

• Exhibit A, Summary of SATF Monitoring Tour Findings

Plaintiffs' Response to Court Expert's Second Report Regarding Treatment of People with Disabilities at SATF

• Declaration of Rita Lomio
• Declaration of Jacob Hutt
• Declaration of Caroline Jackson

Court Expert's Second Report re: Treatment of People with Disabilities at SATF

Order re: Court Expert's Report Regarding Treatment of People with Disabilities at SATF

Plaintiffs' Response to Court Expert's Report on Treatment of People with Disabilities at SATF

Court Expert Report on Treatment of People with Disabilities at SATF

The Court Expert released a report following a year-long investigation of the treatment of people with disabilities at the largest state prison, the California Substance Abuse Treatment Facility and State Prison, Corcoran (SATF). He found that people with disabilities are “living diminished and needlessly difficult lives” at SATF, and as a result “face harsher prison conditions, and thus greater punishment, than their peers.” People were denied accommodations needed to safely and independently perform a wide array of activities, including to eat, perform bodily functions, write, and participate in rehabilitative programs.

Joint Case Management Conference Statement

• Plaintiffs’ Exhibits A-J
• Defendants’ Exhibits A-B

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibit 1-9

Joint Case Management Conference Statement

• Exhibit A-H

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibit A-C

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibit 1-3

Order re: Mandatory Vaccinations

Joint Case Status Statement

Plaintiffs' Reply to Responses to Order to Show Cause re: Vaccination Mandate

• Declaration of Sophie Hart

Receiver's Reply to Responses to Order to Show Cause re: Vaccination Mandate

• Declaration of Dr. Joseph Bick
• Declaration of Tammatha Foss

Plaintiffs' Response to Order to Show Cause re: Vaccination Mandate

• Declaration of Sophie Hart
• Declaration of Rita Lomio
• Declaration of Sara Norman

Supplemental Declaration of Dr. Joseph Bick in Support of Vaccination Mandate

Order Modifying Order to Show Cause re: Vaccination Mandate

Order to Show Cause re: Mandatory Vaccination

Report of J. Clark Kelso, Receiver, Recommending Vaccine Mandate

• Declaration of Dr. Joseph Bick
• Declaration of Tammatha Foss
• Declaration of Dr. Tara Vijayan

Joint Case Management Conference Statement

• Exhibit A

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibits A-C

Fifth Report and Recommendations Regarding Housing of Armstrong Class Members During the COVID-19 Pandemic

Joint Case Management Conference Statement

• Exhibits A-B

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibit A
• Exhibit B
• Exhibit C

Joint Case Management Conference Statement

Joint Case Status Statement

Joint Case Management Conference Statement

• Exhibit A – CDCR Memorandum re Inmates Refusing to Comply with Housing Protocols in Regards to COVID-19 Isolation and Quarantine (Feb. 24, 2021)
• Exhibit B – CDCR Memorandum re COVID-19 Institution Entrance Screening, Testing Procedures and eLearning Course Revised (Feb. 26, 2021)

Joint Case Management Conference Statement

Fourth Report and Recommendations Regarding Housing of Armstrong Class Members During the COVID-19 Pandemic

The Court Expert noted, among other things, that “[t]he fact that, to date, Armstrong class members have been almost five times more likely to die of COVID-19 than non-class members makes the work of protecting them all the more essential.”

Joint Case Management Conference Statement

Joint Case Status Statement (Corrected)

This version has been corrected to note that 45,041 (or 47% of) people incarcerated in California state prisons have tested positive for COVID-19, and 174 people, including at least 83 people with disabilities, have died while in CDCR custody.

Joint Case Management Conference Statement

• Exhibits 1-2

Joint Case Management Conference Statement

• Exhibit A – CCHCS & CDCR Memorandum re: Mandatory Employee COVID-19 Testing and Non-Compliance Accountability (Dec. 21, 2020)

Defendants' Status Report

• Exhibit A – Population as of December 9, 2020
• Exhibit B – CDCR’s Update to the Three-Judge Court

Joint Case Management Conference Statement

• Exhibit A – CDCR & CCHCS Memorandum re: Staff Facial Coverings and Physical Distancing (Dec. 4, 2020)
• Exhibit B – CDCR Memorandum re: Mandatory 14-Day Modified Program (Nov. 25, 2020)
• Exhibit C – CDCR & CCHCS Memorandum re: California’s Regional Stay at Home Order and Departmental Directive (Dec. 4, 2020)

Joint Brief on Quarantine

Third Report and Recommendations Regarding Housing of Armstrong Class Members During the COVID-19 Pandemic

Order Regarding Staff Compliance with Face Covering and Physical Distancing Requirements

Amended Joint Case Management Conference Statement

Joint Case Status Statement

Correction to Second Report and Recommendations Regarding Housing of Armstrong Class Members During the COVID-19 Pandemic

The Court Expert corrected information in his Second Report.  The Court Expert found that as of September 1, 2020:

• At least 108 people at 21 institutions were housed in areas not designated for their disabilities.
• At least one class member was housed in administrative segregation solely because of a disability.
• 42 people with disabilities were housed in temporary or non-traditional areas, including gyms, tents, dayroom cots, and a Prison Industry Authority work area.

Joint Case Management Conference Statement

Second Report and Recommendations Regarding Housing of Armstrong Class Members During the COVID-19 Pandemic

Court Expert’s status update to the Court.  Please note that this Report contains inaccurate factual information, which the Court Expert later corrected in a separate filing on November 6, 2020 (see above).

Joint Case Management Conference Statement

• Exhibit A – In Re Von Staich

Defendants' Status Report

• Exhibits A-B

Joint Case Management Conference Statement

Order Regarding Housing of People with Disabilities During Pandemic

Order requiring CDCR to designate additional isolation and quarantine housing for people with disabilities, and directing evaluation by the Court Expert.

Plaintiffs' Response and Objections to Court Expert's Report and Recommendations Regarding Housing of Armstrong Class Members During COVID-19 Pandemic

For declarations from people with disabilities in unsafe and/or inaccessible housing at Mule Creek State Prison, Deuel Vocational Institution, and the Substance Abuse Treatment Facility, please see the declaration of Patrick Booth.

• Declaration of Patrick Booth
• Declaration of Tania Amarillas Diaz

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Defendants' Declaration and Status Report of Assistant Deputy Director Adam Fouch

Defendants’ attestation of compliance with court order regarding accommodation of people with disabilities during the pandemic, attaching relevant CDCR directives and memoranda.

Court Expert's Report and Recommendations Regarding Housing of Armstrong Class Members During the Covid-19 Pandemic and Exhibits A and B

Court Expert’s report finding “extreme” and “dramatic” deficiencies in accessible quarantine and isolation housing for people with disabilities in California prisons and recommending further judicial action.  For the prison-by-prison analysis, please see Exhibit B.

• Exhibit A
• Exhibit B

Joint Case Status Statement

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Motion to Modify CDCR Plan for Staff Testing for COVID-19

Order to Set Aside Isolation and Quarantine Space

Order Regarding Housing of People with Disabilities During Pandemic

Order requiring the safe, accessible housing of people with disabilities during the pandemic, including for purposes of quarantine and isolation, and directing the Court Expert to review the sufficiency of such housing.

Joint Case Management Conference Statement

Motion to Protect Armstrong Class Members During the COVID-19 Pandemic

Motion challenging CDCR’s failure to safely house and provide accommodations to people with disabilities. We submitted evidence that, for months, Defendants have placed people with disabilities at the California Institution for Men in inaccessible settings. In addition, people with disabilities, including those with significant underlying medical conditions and who are in their 60s, 70s, and 80s, were housed in the same crowded dormitory as people with confirmed, active cases of COVID-19, sharing the same toilets, sinks, showers, dayroom, and sleeping areas, because Defendants had no other accessible housing for them. Unsurprisingly, they quickly became infected.

For more information on the California Institution for Men, see the declarations of Rita Lomio, Patrick Booth, Gay Grunfeld, and Dr. Tara Vijayan. For more information on the California Health Care Facility, Stockton, see declaration of Corene Kendrick.

• Declaration of Rita Lomio
• Declaration of Patrick Booth
• Declaration of Corene Kendrick
• Declaration of Gay Grunfeld
• Declaration of Ernest Galvan
• Declaration of Penny Godbold
• Declaration of Tania Amarillas Diaz
• Declaration of Tara Vijayan, M.D., M.P.H.

Joint Case Management Conference Statement

Joint Case Status Statement

Joint Case Management Conference Statement

Order Regarding Staff Testing for COVID-19

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Joint Case Management Conference Statement

Order Denying Plaintiffs’ Motion

Joint Case Status Statement

Plaintiffs’ Reply in Support of Emergency Motion

• Declaration of Michael Bien
• Declaration of Steven Fama
• Declaration of Thomas Hoffman
• Declaration of James Austin
• Declaration of Patrick Booth

Order

Plaintiffs’ Response to April 6 Order

• Declaration of Marc Stern regarding physical distancing
• Declaration of Michael Bien and Exhibits
• Joint Report Regarding Defendants’ Plans to Achieve Physical Distancing
• Declaration of Michael Bien in Support of Joint Report and Exhibits

Plaintiffs’ Emergency Motion Regarding Prevention and Management of COVID-19

• Declaration of Marc Stern, M.D., regarding medical care
• Declaration of Megan Lynch
• Declaration of Patrick Booth

Order

Order Denying Emergency Motion

Order denying population reduction motion on the basis that Plaintiffs had not first asked the district courts in Plata and Coleman to take action to protect people in prison during the pandemic.

Plaintiffs’ Reply Brief

• Supplemental Expert Declaration of Dr. Marc Stern regarding medical care
• Supplemental Expert Declaration of Thomas Hoffman regarding parole operations
• Expert Declaration of James Austin, Ph.D., regarding risk assessments of incarcerated people
• Declaration of Donald Specter

Request for Judicial Notice of other courts’ orders and directives releasing incarcerated people

Emergency Motion

Motion before the three-judge panel in Plata and Coleman, seeking an order to immediately reduce the prison population because of the unacceptable risk of harm from COVID-19.

• Proposed Order
• Declaration of Dr. Craig Haney regarding mental health care
• Declaration of Dr. Marc Stern regarding medical care
• Declaration of Thomas Hoffman regarding operations/custody issues
• Declaration of Megan Lynch (and photos of conditions in CDCR prisons), Exhibit A and Exhibits B-D
• Declaration of Michael Brodheim regarding conditions at California Medical Facility, Vacaville, CA
• Declaration of Shira Tevah regarding conditions at CDCR prisons
• Declaration of Michael Bien, and Exhibits 1-16 and Exhibits 17-47