Court finds Sheriff Patrick Labat in Breach for Second Time in Jail Conditions Case

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Atlanta Daily World
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Lawsuit on behalf of women with serious mental illness who were left to languish in their cells under deplorable conditions
On August 7, 2025, U.S. Magistrate Judge Regina D. Cannon found Fulton County Sheriff Patrick Labat in breach of the settlement agreement in Georgia Advocacy Office, et al. v. Labat for a second time, stating that he “ultimately is responsible for his own noncompliance.”
In April 2019, the Southern Center for Human Rights and the Georgia Advocacy Office filed a lawsuit on behalf of women with serious mental illness held in torturous conditions of solitary confinement in the South Fulton Jail in Union City, Georgia. The law firm of Caplan Cobb LLC joined the lawsuit several months later on behalf of women detained at the jail. Plaintiffs presented photographs from an inspection by the Georgia Advocacy Office showing garbage-strewn cells, standing toilet water on the floor, a trail of urine flowing from a cell door, bloody clothes and underwear stained with fecal matter lying in the living areas, toilets full of garbage, and feces and blood on the walls. These women, most of whom were caged for petty offenses, sometimes remained in their squalid cells around the clock for weeks or months on end.
After calling the conditions in the South Fulton Jail “repulsive,” U.S. District Court Judge William Ray II approved a settlement agreement in April 2022 aimed at remedying the human rights violations the women in this class action face daily. Among other things, the agreement required:
  • At least four hours of out-of-cell time, five days a week (one hour of which must be recreation time), with an hour of out-of-cell time offered on the other two days of the week for people with serious mental illness;
  • Opportunities for meaningful therapeutic activities;
  • Access to clean drinking water, personal hygiene items, reading materials, a sufficient supply of clothing and underwear, and a quality control process so that people are no longer served moldy, spoiled food;
  • Training for correctional staff supervising people with serious mental illness; and
  • A reliable tracking system to ensure people with serious mental illness are receiving required out-of-cell time.
Three years later, an independent court monitor concluded the Sheriff’s compliance had worsened since the first breach finding. Through continued investigation the litigation team provided further evidence supporting a second filing of material breach, including hundreds of instances where jail staff improperly documented denials of out-of-cell time as refusals.
On August 7, 2025, Judge Cannon, citing the litigation team’s investigation, ruled that Sheriff Labat remains non-compliant with several critical requirements by failing to:
  1. Provide accurate or consistent records to track compliance with the agreement;
  2. Abide by the agreement’s tracking, reporting, and documentation requirements by failing to “maintain a record of the exact times” for each woman with respect to each form of out-of-cell time offered, denied, or refused;
  3. Maintain or provide accurate lists of women with serious mental illness;
  4. Offer access to reading material; and
  5. Comply with the agreement’s staffing, training, and supervision requirements.
Labat contended that he has complied with the settlement agreement; however, Judge Cannon called Sheriff Labat’s arguments “hollow.” In her order, she characterized his documentation practices as “suspect,” chided the Sheriff for claiming that the testimony and declarations of women in the jail are inherently unreliable, and called into question his claim on the one hand that he can’t comply with the agreement, while claiming on the other that he has sufficient resources to comply.
“This ruling is more than a finding in favor of the Plaintiffs — it is a reminder that the women inside that jail are human beings whose voices matter. For too long, they have reported poor and degrading conditions, and those reports have been ignored,” said Devon Orland, Litigation Director at Georgia Advocacy Office. “The court’s order affirms what should never have been in question: these women have value, their experiences carry weight, and the Sheriff is not above the law when it comes to their treatment.”
“The order is essential to holding the Sheriff accountable for his repeated disregard of the settlement agreement.” Jarred Klorfein, Partner at Caplan Cobb LLC.
Sheriff Labat has asked the U.S. District Court to review the magistrate’s order. Because this is the second finding of material breach, the U.S. District Court can convert the existing settlement agreement into a consent decree and order sanctions if he agrees with the magistrate’s findings.
“Fulton County agreed to make meaningful changes in the lives of people with psychiatric disabilities, and it has failed to live up to its end of the bargain time after time. As long as we rely on jails to treat serious mental illness, we will continue to see the types of violations that have repeatedly been brought before the Court,” said Atteeyah Hollie, Deputy Director at the Southern Center for Human Rights.
Case Timeline:
  • April 2019-Class-action filed, alleging conditions of confinement at the South Fulton Jail violated their constitutional rights
  • July 15-18, 2019-Evidentiary hearing, (July 23, 2019)-Court granted a preliminary injunction in favor of our clients
  • April 4, 2022-District Judge William Ray II issued a final order approving joint settlement
  • December 2022-Women with serious mental illness moved to Atlanta City Detention Center (ACDC) from South Fulton Jail
  • March 30, 2023-Plaintiffs filed a motion for material breach (contempt)
  • October 5, 2023– Hearing held for arguments on motion
  • January 2, 2024-Magistrate Court Order finding Defendant in material breach (contempt)
  • June 18, 2024– District Court Order affirming Defendant in material breach (contempt)
  • July 19, 2024-Independent Monitor Downgrading Defendant’s Compliance Rating-Supplemental Brief in Support of Plaintiff’s Motion for Second Finding of Material Breach (Contempt)
  • August 16, 2024– Reply Brief in Support of Plaintiff’s Motion for Second Finding of Material Breach
  • August 29, 2024-Oral argument on second motion for material breach
  • August 7, 2025– Magistrate Court Order finding Defendant in material breach for a second time
To read the pleadings, please visit www.schr.org
For additional information, contact Kathryn Hamoudah at 404/688-1202 or khamoudah@schr.org

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