Human Rights Group CCHR To Organize Protest in the Death of Skye Baskin that spent weeks or months languishing in jail, often in isolation and without treatment, while his condition worsened.

 MOTION FOR CONTEMPT & REMEDIAL ORDER Disability Rights Oregon Page 2 511 SW 10th Avenue, Suite 200 Portland, OR 97205 (503) 243-2081 I. Motion Plaintiff Disability Rights Oregon (DRO) hereby moves this Court pursuant to its inherent authority to enforce its own orders, to impose civil contempt sanctions, and to issue writs to require compliance with its own injunctions or judgements. See Stone v. City & Cnty. of San Francisco, 968 F.2d 850, 856 (9th Cir. 1992), as amended on denial of reh’g (Aug. 25, 1992) (federal courts have “wide latitude” and “inherent power” to enforce their “lawful orders through contempt). The federal rules confer on federal courts the authority to issue injunctions. Fed. R. Civ. Pro. 65. The rules specify who is bound by those orders, including the “parties” to a case. Fed. R. Civ. Pro. 65(d)(2). The All Writs Act also provides federal courts with the ability to safeguard the integrity of their proceedings and judgments. 28 U.S.C § 1651(a)(“The Supreme Court and all courts established by Act of Congress may issue all writs necessary or appropriate in aid of their respective jurisdictions and agreeable to the usages and principles of law.”); see also Doe #1 v. Trump, 458 F.Supp.3d 1220, 1223 (“There must be some connection between the underlying claims and the newly-challenged conduct for that conduct sufficiently to interfere with the Court’s jurisdiction to support an extraordinary writ under the All Writs Act”). Plaintiff DRO respectfully asks this Court to use its “inherent power to enforce compliance” with its own permanent injunction and to issue appropriate remedial orders including but not limited to levying civil contempt. Shillitani v. United States, 384 U.S. 364, 370 (1966). II. Brief Memorandum In 2002, after a bench trial, this Court issued a permanent injunction requiring Defendants to “ensure that persons who are declared unable to proceed to trial” be committed “as soon as practicable” to the state psychiatric hospital or other suitable treatment facility “in a Case 3:02-cv-00339-AN Document 540 Filed 01/07/25 Page 2 of 26 MOTION FOR CONTEMPT & REMEDIAL ORDER Disability Rights Oregon Page 3 511 SW 10th Avenue, Suite 200 Portland, OR 97205 (503) 243-2081 reasonably timely manner, and completed not later than seven days after the issuance” of an appropriate order finding the individual unfit to proceed to trial. ECF 51. For years, Defendants maintained compliance with the permanent injunction. However, starting in the Fall of 2018, Defendants have been largely out of compliance with only brief periods of compliance. At the last hearing in this matter, Defendants stated that they had no projection of when they would come back into compliance with the permanent injunction. Cooper Decl. Ex. A at 27. During the last few years of noncompliance, at least two jail detainees found unable to aid and assist have died while waiting for a hospital bed, as a result of complications of their mental illnesses and the related inability to eat or drink. Cooper Decl. at ¶3-5. Hundreds of other detainees have spent weeks or months languishing in jail, often in isolation and without treatment, while their conditions worsened. The human costs of Defendants’ noncompliance have been enormous. Plaintiff DRO seeks relief from this Court due to Defendants lack of an immediate plan to comply with the permanent injunction. III. Procedural History Plaintiffs filed a complaint in this matter on March 19, 2002, alleging tha