Federal Contracts Do Not “Federalize” Municipal Detention Facilities: First Circuit Confirms § 1983 State-Action Status for Wyatt Officials

Introduction

In Wright v. Martin, the United States Court of Appeals for the First Circuit addressed a recurring threshold question in jail and prison litigation: when do officials at a detention facility act “under color of state law” for purposes of 42 U.S.C. § 1983? The appellant, David Daoud Wright, a Sunni Muslim confined at the Donald W. Wyatt Detention Facility in Central Falls, Rhode Island from January 2020 to June 2021 while awaiting resentencing on federal charges, alleged that the facility’s warden and other officials infringed his rights under the First and Fourteenth Amendments by denying access to congregational prayer in the chapel, harassing him for his religious observance, and retaliating by facilitating his transfer after he complained.

Proceeding pro se, Wright sued the then-warden, Daniel W. Martin, and three unknown officials under § 1983. The district court dismissed his complaint under Rule 12(b)(6), relying on a previous District of Rhode Island decision, Glennie v. Garland, which had characterized Wyatt officials as acting under color of federal law—and therefore outside § 1983’s reach. The First Circuit reversed, holding that Wright plausibly alleged action under color of state law and clarifying a legally significant point: municipal officials running a municipally owned and operated detention facility remain state actors for § 1983 purposes, even when housing federal detainees under contract with federal agencies.

Summary of the Opinion

Writing for a unanimous panel (Judges Montecalvo, Lipez, and Aframe), Judge Lipez reversed the district court’s dismissal. The court drew several key conclusions:

Wyatt is operated by the Central Falls Detention Facility Corporation (CFDFC), a public corporation that is an “instrumentality and agency” of the City of Central Falls, governed by a board appointed by the city’s mayor and approved by the city council. As such, for constitutional purposes, CFDFC is a municipal entity.
The fact that Wyatt houses federal detainees pursuant to a contract with the U.S. Marshals Service does not “federalize” the facility or its employees. Absent deputization or federal control over day-to-day operations, municipal employees remain state actors.
Accordingly, Wright’s complaint plausibly alleges that the warden and officials acted under color of state law, allowing his § 1983 claims to proceed past the pleading stage.

The court distinguished earlier District of Rhode Island cases (Sarro and LaCedra) and Glennie on the critical factual point that, at the time of those decisions, Wyatt was understood to be privately operated by Cornell Corrections, whereas it is now operated by CFDFC itself. Relying on Supreme Court and sister-circuit authority, the First Circuit aligned with the majority view that municipal jailers do not become federal actors merely by contracting to house federal detainees. The case was remanded for further proceedings.

Analysis

1) Precedents and Authorities Cited

The First Circuit’s reasoning is rooted in a well-developed body of law regarding state action under § 1983 and the constitutional status of government-created corporations:

West v. Atkins (U.S. 1988) and Boniface v. Viliena (1st Cir. 2025): These authorities provide the core state-action test for § 1983: a defendant acts “under color of state law” when exercising power “possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law.” The court uses this framework to evaluate the CFDFC and its officials.
Lebron v. National Railroad Passenger Corp. (U.S. 1995): The Supreme Court recognized that government-created and -controlled corporations are, for constitutional purposes, part of the government. The First Circuit leverages Lebron to characterize CFDFC—created by state statute, embedded in municipal governance, and endowed with statutory powers over Wyatt—as a governmental entity whose employees act with state authority.
Belbachir v. County of McHenry (7th Cir. 2013) and Henderson v. Thrower (5th Cir. 1974): These cases directly support the proposition that municipal or county officials remain state actors, even when they house federal detainees under federal contracts. The Seventh Circuit emphasized that such contracts do not “federalize” local jails, while the Fifth Circuit explained that local officials derive authority from their state positions, not from detainees’ federal status.
Logue v. United States (U.S. 1973): Though an FTCA case, Logue complements the court’s analysis by recognizing that county jailers remain county employees overseeing federal prisoners under contract, rather than federal employees themselves.
Third, Tenth, and Fourth Circuit decisions (E.D. v. Sharkey; Porro v. Barnes; Loe v. Armistead): These align with Belbachir/Henderson, endorsing § 1983 as the right vehicle for claims by federal detainees housed in local facilities.
District-level authorities (Li v. City of Santa Ana; Green v. Scarbrough): Recent decisions rejecting arguments that federal contracts “completely federalize” local jails where they continue to house nonfederal detainees and maintain local control.
Rhode Island statutory framework (R.I. Gen. Laws §§ 45-54-1 et seq.): The statute creates CFDFC as a public corporation and municipal instrumentality with expansive powers over Wyatt, including rulemaking on religious services and the hiring, retention, and discipline of employees. These provisions ground the conclusion that CFDFC is a municipal governmental actor.
Prior District of Rhode Island cases (Sarro v. Cornell Corrections; LaCedra v. Wyatt; Glennie v. Garland): The First Circuit treats these as context-dependent and ultimately distinguishable because they addressed a privately operated Wyatt. The decisive development is CFDFC’s resumption of operations (no longer Cornell Corrections).

2) The Court’s Legal Reasoning

The panel’s analysis proceeds in logical steps tied to the pleading standard and the structure of Rhode Island law:

Pleading posture and standard: On de novo review of a Rule 12(b)(6) dismissal, the court accepts well-pleaded facts as true and draws reasonable inferences for the plaintiff. The court also notes that public records may be considered and, critically, accepts defense counsel’s on-the-record representation that CFDFC—not a private contractor—runs Wyatt and employs its officials, citing the principle that key information may be within defendants’ control at the motion-to-dismiss stage.
Municipal character of CFDFC/Wyatt: R.I. Gen. Laws § 45-54-1(a) defines CFDFC as a public corporation and an instrumentality/agency of the City of Central Falls, with governance by city-appointed and council-approved directors. CFDFC’s statutory powers include control over detainee care, staffing, and the promulgation of rules—including those governing religious services. That is textbook state authority. Under Lebron, government-created and -controlled corporations are, for constitutional purposes, governmental actors. Thus, Wyatt officials employed by CFDFC act with authority derived from state law.
Purpose of the enabling statute: While the Act sought to address federal detention needs, it also pursued state economic development goals. Historically, CFDFC contracted to house federal and nonfederal detainees alike, and nothing in the statute mandates exclusive federal use. The Act’s mixed purposes reinforce the conclusion that CFDFC serves state interests through a state-created mechanism, rather than functioning as a federal agency.
Effect of federal contracting: The panel expressly rejects the notion that a contract with the U.S. Marshals Service “federalizes” a municipal facility or converts its employees into federal actors. Echoing Belbachir and Henderson, the court observes that where a local jail continues to house nonfederal detainees and there is no allegation of federal deputization or day-to-day operational control by a federal agency (including over religious policies), the municipal character of the actors remains intact. State power—not federal delegation—explains the officials’ authority and obligations.
Distinguishing private-operator cases: The court underscores that earlier decisions (Sarro, LaCedra, Glennie) operated on the premise that Wyatt was privately run by Cornell Corrections. That premise no longer holds. In the current posture, the defendants are municipal employees, and private-actor state-action tests are inapposite. This factual pivot reshapes the analysis and dictates a different outcome.

In sum, because Wright’s allegations support the inference that Martin acted under color of state law, the district court’s dismissal was erroneous. The court reversed and remanded for further proceedings, without reaching the merits of Wright’s First and Fourteenth Amendment claims.

3) Impact and Implications

The decision carries several practical and doctrinal consequences:

State-action clarity for mixed-use facilities: The First Circuit joins a strong consensus that municipal or county detention officials remain subject to § 1983 even when federal detainees are housed under federal contracts. This clarity matters in jurisdictions where local facilities regularly contract with federal agencies (e.g., U.S. Marshals Service, ICE, Bureau of Prisons) while retaining municipal governance and control.
Course correction from Glennie: Although the court did not directly overrule Glennie (a district court decision), it effectively limits Glennie’s reach by clarifying that its analysis hinged on the assumption of private operation. Where Wyatt (or a similar facility) is municipally operated, § 1983 claims against its officials are viable.
Pathway for federal detainees in local custody: Federal detainees housed in municipal facilities within the First Circuit can sue local officials under § 1983 for constitutional violations. This avoids the need to fit claims into the disfavored and sharply limited Bivens framework, which applies to federal actors and has been significantly constrained by the Supreme Court in recent years. Although this opinion does not discuss Bivens, its state-action analysis naturally channels such cases into § 1983 when the defendants are local officials.
Municipal liability questions on remand: The opinion concerns individual capacity claims under § 1983 against the warden and John Does. If plaintiffs seek to impose municipal liability (for example, on a theory that CFDFC policies or customs restricted religious exercise), they will have to satisfy the Monell standard—showing a policy, custom, or practice that caused the constitutional violation. Although not decided here, the statutory grant of rulemaking authority over religious services to CFDFC could make Monell-type arguments salient in future litigation.
Religious exercise and retaliation claims revived: By restoring § 1983 jurisdiction, the panel allows Wright’s First Amendment free exercise and retaliation claims (as channeled through § 1983 and the Fourteenth Amendment) to proceed. The merits will likely require application of standards for detainees’ religious exercise (e.g., within the contours of penological interests) and for retaliation (protected activity, adverse action, causal connection), none of which the court reached at this stage.
Procedural guidance at the pleading stage: The court’s willingness to credit defense counsel’s representations about the facility’s current operator reflects a practical recognition that such facts are often within defendants’ control. Paired with the allowance to consult public records, this approach encourages early clarification of the facility’s governance status, which can be outcome-determinative for § 1983.

Complex Concepts Simplified

“Under color of state law”: For a § 1983 claim, the defendant must be acting with power granted by state law—i.e., using official authority as a state or local official. If the defendant is a federal actor, § 1983 does not apply; a plaintiff would then consider other avenues (e.g., Bivens)—though those are limited.
Public corporation vs. private operator: A public corporation like CFDFC is created by statute, controlled by public officials, and exercises public powers. Its employees act with governmental authority. A private operator is a private company contracted to run a facility; whether its employees’ actions count as “state action” depends on specific “private actor” tests. That distinction is central here.
Federal contracts do not equal federal actors: A local facility’s contract with a federal agency to house detainees does not make the facility federal. Unless the federal government takes over daily operations or deputizes local staff, local staff remain local (state) actors for § 1983 purposes.
Rule 12(b)(6) plausibility standard: At the motion-to-dismiss stage, the complaint must allege enough facts to make a claim “plausible.” Courts take well-pleaded facts as true and draw reasonable inferences for the plaintiff, without weighing evidence. Here, that standard favored treating Wyatt’s officials as state actors given CFDFC’s role.
Lebron’s significance: The Supreme Court in Lebron held that government-created and -controlled corporations are governmental actors for constitutional purposes. That precedent undergirds the First Circuit’s treatment of CFDFC as part of municipal government.
Remand implications: Reversal at this stage does not decide the constitutional merits (e.g., whether the denial of congregational prayer or transfer was unlawful). It simply allows Wright to proceed to discovery and further litigation on his § 1983 claims.

Conclusion

Wright v. Martin establishes an important state-action principle within the First Circuit: employees of a municipally owned and operated detention facility remain state actors subject to § 1983—even when housing federal detainees under a federal contract. The panel’s analysis is rooted in Rhode Island’s statutory framework for CFDFC, Supreme Court guidance on public corporations, and a broad consensus from other circuits rejecting the “federalization” of local jails by contract alone.

By reversing the district court’s dismissal, the First Circuit reopens the courthouse doors for detainees alleging constitutional violations by municipal jailers in mixed-use facilities. On remand, Wright will be able to pursue his allegations that he was denied congregational prayer and retaliated against for religious complaints. More broadly, the opinion provides a clear roadmap for courts and litigants facing the threshold § 1983 question in jurisdictions where local detention facilities cooperate with federal authorities: unless federal agencies take over operations or deputize local staff, municipal officers remain state actors, and § 1983 remains the correct vehicle for constitutional claims.