Edwards v. Witherspoon, et al.
4th Cir. No. 24-7049
While she was pregnant and giving birth, Ms. Edwards was shackled by North Carolina prison officials and then cut off from the medication that treated her opioid use disorder. She is fighting to hold those officials accountable, and the Fourth Circuit has cleared the way for her case to go to trial.
Rights Behind Bars represents Tracey Edwards, who was incarcerated at the North Carolina Correctional Institution for Women (NCCIW) when she learned during intake that she was pregnant with her second child. Ms. Edwards lives with opioid use disorder, and while she was pregnant the prison gave her a daily dose of Suboxone—medication for opioid use disorder (MOUD)—that kept her stable and safe.
When officers took her to the hospital to give birth in December 2019, they shackled her by one wrist and one ankle to the bed through induction and active labor; the restraints came off only when doctors told her to push. Soon after giving birth she was chained again, and she was later returned to the prison in a belly chain, leg irons, and handcuffs. The shackling caused severe pain and interfered with her ability to hold and bond with her newborn—all in violation of the prison's own written policy limiting restraints on pregnant people.
Once Ms. Edwards was back at NCCIW and no longer pregnant, the prison refused to continue her MOUD, invoking a rule that offered the medication only to pregnant people. She spent weeks in an unnecessary, dangerous withdrawal she described as "more painful than giving birth."
Ms. Edwards sued state and prison officials under 42 U.S.C. § 1983, alleging that both the shackling and the denial of MOUD violated the Eighth Amendment, and that refusing her MOUD violated Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. The district court granted defendants’ motion for summary judgment, dismissing Ms. Edwards’ claims.
Rights Behind Bars represented Ms. Edwards in the district court and on appeal. In a published opinion, the Fourth Circuit allowed her core claims to proceed to trial. The court held that "shackling a pregnant offender during labor and immediately postpartum poses an objectively serious risk of harm under the Eighth Amendment," reviving the claim against the warden and four officers because the wrongfulness of the conduct was obvious. On the medication claim, it held that a jury could find the prison's medical director and health treatment administrator deliberately indifferent for enforcing a blanket policy that denied MOUD to everyone who was not pregnant. Recognizing the "growing recognition that substance abuse and OUD are disabilities," the court also held that the district court had wrongly treated Ms. Edwards' disability claims as being about her pregnancy rather than her opioid use disorder.
The case now returns to the district court, where Ms. Edwards continues to pursue accountability.