Wharton v. Danberg

In 2008, the Delaware correctional system was facing scandal for its handling of inmate releases. One inmate committed suicide in his cell on the day he was supposed to be—but was not—released. Dozens of others had either been released too early or too late. Reform consisted of establishment of a new Central Offender Records office within the Delaware Department of Corrections. Inmates who were over-detained sued top correctional officials in a putative class action, claiming that Delaware’s problems with over-detentions have, if anything, gotten worse since 2008. The Third Circuit affirmed summary judgment in favor of the defendants. The court noted that “hard, reliable data about the number of over-detentions occurring each year is more or less missing from the record.” To survive summary judgment on an allegation of deliberate indifference, the plaintiffs needed more than speculation connecting any increase in over-detentions with the COR policies they deem ineffective. View "Wharton v. Danberg" on Justia Law