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746 KB
Extraction Summary
6
People
3
Organizations
1
Locations
3
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
746 KB
Summary
This legal document, part of case 1:20-cr-00330-PAE filed on June 15, 2022, argues that the pre-sentence detention conditions of Ms. Maxwell at the MDC constitute cruel and unusual punishment in violation of the Eighth Amendment. The filing claims her treatment is significantly harsher than that of the general prison population and was implemented under specific directives from then-Attorney General William Barr, who was intent on avoiding a repeat of the incident involving Epstein in BOP custody. The document asserts this disparate and punitive treatment was condoned by MDC supervisors and wardens.
People (6)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Pretrial detainee |
The subject of the document, whose conditions of confinement are being argued as cruel and unusual punishment.
|
| William Barr | then-Attorney General |
Mentioned as having issued directives for Ms. Maxwell's treatment following the incident with Epstein.
|
| Epstein |
Mentioned in reference to an event that occurred while he was in BOP custody, which influenced the directives for Ms....
|
|
| John F. Stinneford | Author |
Cited in footnote 19 for his articles on the meaning of "Cruel" and "Unusual" in the Eighth Amendment.
|
| Trop | Party in a legal case |
Mentioned in the case citation Trop v. Dulles in footnote 18.
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| Dulles | Party in a legal case |
Mentioned in the case citation Trop v. Dulles in footnote 18.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC | government agency |
Metropolitan Detention Center, the facility where Ms. Maxwell is detained. Mentioned as retaining unchecked authority...
|
| BOP | government agency |
Bureau of Prisons, mentioned along with the MDC as officials who retained unchecked authority over Ms. Maxwell's inca...
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| Supreme Court | government agency |
Cited for its definition of "unusual" punishment.
|
Timeline (3 events)
Ms. Maxwell's pre-sentence detention under conditions described as long-term isolation, unusual restrictions, and deprivation, constituting cruel and unusual punishment.
MDC
Following Ms. Maxwell's arrest, then-Attorney General William Barr issued directives to be applied exclusively to her, intended to prevent a repeat of what happened to Epstein in BOP custody.
Approximately ten wardens have rotated in and out of the MDC during Ms. Maxwell's detention.
MDC
Locations (1)
| Location | Context |
|---|---|
|
The location of Ms. Maxwell's detention, where approximately ten wardens have rotated through during her confinement.
|
Relationships (3)
The document states that 'complaints made by Ms. Maxwell and her counsel' were made regarding her treatment.
The document alleges that MDC and BOP officials subjected Ms. Maxwell to unusual punishment and retained unchecked authority over her incarceration.
Barr, as Attorney General, issued directives specifically concerning the conditions of Ms. Maxwell's confinement.
Key Quotes (2)
"something different from that which is generally done."Source
— The Supreme Court
(The Supreme Court's definition of the term "unusual" in the context of punishment.)
DOJ-OGR-00010476.jpg
Quote #1
"a punishment is cruel and unusual if it is overly harsh in light of longstanding practice."Source
— Legal interpretation
(A statement describing the original understanding of the Cruel and Unusual Punishment Clause, citing John F. Stinneford.)
DOJ-OGR-00010476.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,192 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 30 of 77
confinement, conditions far more arduous than those experienced by pretrial detainees, or even
sentenced prisoners, in general population. Beyond duration of confinement (the quantitative
measure of imprisonment), she was subjected to disparate treatment (e.g., long-term isolation and
unusual restrictions and deprivation) amounting to a profound qualitative difference.
sentenced prisoners, in general population. Beyond duration of confinement (the quantitative
measure of imprisonment), she was subjected to disparate treatment (e.g., long-term isolation and
unusual restrictions and deprivation) amounting to a profound qualitative difference.
Pre-Sentence Detention Should Not Be Pre-Sentence Punishment
Convicted offenders are sent to prison as punishment, not for punishment. Despite
complaints made by Ms. Maxwell and her counsel, the MDC and BOP officials retained unchecked
authority to incarcerate her as they pleased on conditions that constituted unusual punishment for
a non-violent pretrial detainee who posed no threat to herself or others. Ms. Maxwell bore the
brunt of unusual conditions imposed by unfettered prison bureaucrats. The Supreme Court defines
“unusual” as “something different from that which is generally done.”¹⁸ Under an original
understanding of the Cruel and Unusual Punishment Clause (U.S. Const. amend. viii), “a
punishment is cruel and unusual if it is overly harsh in light of longstanding practice.”¹⁹ Ms.
Maxwell’s conditions of confinement were significantly and unjustifiably harsher than conditions
in general population making it cruel and unusual under the Eighth Amendment. Following Ms.
Maxwell’s arrest, then-Attorney General William Barr was intent on making sure what happened
to Epstein while in BOP custody would not be repeated and issued directives to be applied
exclusively to Ms. Maxwell. The rough, discriminatory, and punitive treatment was implemented
and condoned by supervisors and wardens.²⁰ High-ranking MDC personnel, psychologists, and
complaints made by Ms. Maxwell and her counsel, the MDC and BOP officials retained unchecked
authority to incarcerate her as they pleased on conditions that constituted unusual punishment for
a non-violent pretrial detainee who posed no threat to herself or others. Ms. Maxwell bore the
brunt of unusual conditions imposed by unfettered prison bureaucrats. The Supreme Court defines
“unusual” as “something different from that which is generally done.”¹⁸ Under an original
understanding of the Cruel and Unusual Punishment Clause (U.S. Const. amend. viii), “a
punishment is cruel and unusual if it is overly harsh in light of longstanding practice.”¹⁹ Ms.
Maxwell’s conditions of confinement were significantly and unjustifiably harsher than conditions
in general population making it cruel and unusual under the Eighth Amendment. Following Ms.
Maxwell’s arrest, then-Attorney General William Barr was intent on making sure what happened
to Epstein while in BOP custody would not be repeated and issued directives to be applied
exclusively to Ms. Maxwell. The rough, discriminatory, and punitive treatment was implemented
and condoned by supervisors and wardens.²⁰ High-ranking MDC personnel, psychologists, and
¹⁸ Trop v. Dulles, 356 U.S. 86, 100-01 n.32 (citations omitted).
¹⁹ John F. Stinneford, The Original Meaning of “Cruel,” 105 GEO. L.J. 441, 467 (2017); The Original
Meaning of Unusual: The Eighth Amendment as a Bar to Cruel Innovation, 102 NW. U. L. Rev. 1739,
1745 (2008)
²⁰ During Ms. Maxwell’s detention, approximately ten wardens have rotated in an out of the MDC.
¹⁹ John F. Stinneford, The Original Meaning of “Cruel,” 105 GEO. L.J. 441, 467 (2017); The Original
Meaning of Unusual: The Eighth Amendment as a Bar to Cruel Innovation, 102 NW. U. L. Rev. 1739,
1745 (2008)
²⁰ During Ms. Maxwell’s detention, approximately ten wardens have rotated in an out of the MDC.
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