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To establish a deliberate-indifference claim, a plaintiff must make both an objective and a subjective showing. Under the objective component, the plaintiff must demonstrate a substantial risk of serious harm. Under the subjective component, the plaintiff must prove the defendants' deliberate indifference to that risk of harm by making three sub-showings: (1) subjective knowledge of a risk of serious harm; (2) disregard of that risk; (3) by conduct that is more than mere negligence. The inquiry thus hinges on whether the defendants disregarded the risk by conduct that is more than mere negligence or more simply stated, whether they recklessly disregarded that risk.
A group of medically vulnerable inmates challenged the conditions of their confinement at Miami's Metro West Detention Center. In particular, they asserted that Miami-Dade County and Daniel Junior, the Director of the Miami-Dade Corrections and Rehabilitations Department, have inadequately responded to the COVID-19 outbreak and thereby violated their constitutional rights. Holding that the plaintiffs were likely to succeed on the merits of their claim and would suffer irreparable injury in the absence of immediate relief, the United States District Court for the Southern District of Florida enjoined the county and Junior to take a number of precautionary measures to halt the virus' spread and ordered them to file regular reports regarding the virus' status.
Did the inmates successfully establish their deliberate indifference claim?
The court held that the district court erred in granting medically vulnerable inmates a preliminary injunction enjoining defendants, the county and the director of corrections, to take precautionary measures to halt the spread of COVID-19 because the inmates failed to demonstrate the likelihood of success on the merits of their Eighth and Fourteenth Amendment deliberate indifference claim as neither the resultant harm of increasing infections nor the impossibility of achieving six-foot social distancing in a jail environment established that defendants acted with a deliberately indifferent mental state, equivalent to subjective recklessness as used in the criminal law.