As the coronavirus pandemic exacerbated existing racial, economic, and health disparities, it also raised questions concerning congressional intent, administrative rights, and federal court powers. These issues flooded court dockets as detained populations sought relief pursuant to the compassionate release provision of the First Step Act. Given the virus’s rapid development and fatal consequences, many prisoners found themselves pressed for time and disinclined to spend it exhausting statutorily-mandated administrative requirements. The question as to whether judges may develop equitable exceptions to these procedural requirements has remained unanswered. This Note responds in the affirmative, concluding the authority vests itself when remedies are unavailable.
Yale Law School, J.D. 2022.