Take 5

Fifth Circuit Court of Appeals Overturns Earlier Decision in Case of Overdetention

The United States Court of Appeals for the Fifth Circuit has issued a ruling overturning its prior decision in the case of Percy Taylor v. James LeBlanc, Secretary of the Louisiana Department of Public Safety and Corrections. The court released the new ruling on May 15, 2023, and declared that the earlier opinion, Taylor v. LeBlanc, 60 F.4th 246 (5th Cir. 2023), was withdrawn and replaced.

At the core of the case is a violation of the Fourteenth Amendment, which prohibits states from depriving any person of life, liberty, or property, without due process of law. Percy Taylor, the plaintiff in the case, was held in prison beyond the expiration of his sentence, a violation of his constitutional rights. The case was an appeal against James LeBlanc, the head of the Louisiana Department of Public Safety and Corrections, who had been denied qualified immunity in a lower court ruling.

The issue of wrongful detention came to light following a study conducted by the Louisiana Department of Public Safety and Corrections. The study revealed a substantial number of inmates who were detained longer than their sentences due to poor communication between local jails and the Department. This caused delays in crediting jailtime, resulting in prisoners remaining in prison beyond their sentences.

Percy Taylor, however, was overdetained for a different reason. He had served two consecutive sentences, but Department officials gave him credit for pre-trial detention for only one of the sentences. This was compliant with the law at the time but contradicted a more generous provision in effect when Taylor’s sentence was entered. Consequently, Taylor served over a year longer than he should have.

Upon release, Taylor brought a suit against various Louisiana officials, including James LeBlanc, under 42 U.S.C. § 1983, among other claims. The court’s decision in this appeal concerned only Taylor’s claim against LeBlanc. LeBlanc appealed the denial of qualified immunity, arguing that his conduct wasn’t objectively unreasonable in light of clearly established law.

In the court’s opinion, Circuit Judge James C. Ho stated that while the right to timely release is clearly established, Taylor did not show how LeBlanc’s conduct was objectively unreasonable in light of clearly established law. Taylor argued that LeBlanc was unreasonable because he failed to assign the task of calculating release dates to an attorney, but the court found that nothing in the Constitution requires such actions to be undertaken by a member of the bar.

The court thus ruled in favor of LeBlanc, reversing the lower court’s denial of qualified immunity. This decision underscores the importance of clear and consistent communication between local jails and the Department, as well as the need for accurate calculation of prisoners’ sentences.

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