Amici—leading medical and addiction-medicine organizations—argue that Opioid Use Disorder (OUD) is a chronic brain disease and that the evidence-based standard of care is Medication-Assisted Treatment (MAT), especially agonist maintenance with methadone or buprenorphine, which markedly reduces relapse and mortality. By contrast, “detox” or withdrawal-only approaches are outdated, unsafe, and ineffective; studies show relapse rates exceeding 90%, often within a week, and forced withdrawal lowers tolerance and heightens overdose risk. The jail’s policy—terminating any existing MAT on admission, providing no MAT during withdrawal, and giving at most a single pre-release naltrexone injection—ignores clinical judgment, fails to individualize care, and substitutes an inferior, non-MAT regimen that the literature does not support. Because patients respond differently to methadone, buprenorphine, and naltrexone, nonclinical substitution or cessation of a proven, working methadone plan (as with the plaintiff) delivers substandard care and foreseeably triggers relapse, overdose, and death. Amici contend such a one-size-fits-all, non-MAT protocol is not “commensurate with modern medical science” or “acceptable within prudent professional standards,” so it is not entitled to deference. They urge the Court to order continuation of the plaintiff’s methadone maintenance during his short incarceration.

Summary

Leading medical and addiction-medicine organizations contend that Opioid Use Disorder (OUD) is a chronic neurological condition. The established standard of care involves Medication-Assisted Treatment (MAT), particularly agonist maintenance therapies such as methadone or buprenorphine. These treatments significantly reduce the likelihood of relapse and decrease mortality rates. In contrast, approaches focused solely on withdrawal, often termed "detoxification," are considered outdated, pose safety risks, and have proven ineffective. Research indicates that relapse rates for these methods frequently surpass 90%, often occurring within a week. Furthermore, forced withdrawal reduces an individual's tolerance to opioids, thereby increasing the danger of overdose. Current jail policies, which include discontinuing existing MAT upon admission, withholding MAT during the withdrawal phase, and administering at most one pre-release naltrexone injection, disregard professional clinical judgment. Such policies fail to provide individualized care and implement an inferior, non-MAT regimen that lacks support in medical literature. Given that individuals respond differently to methadone, buprenorphine, and naltrexone, the non-clinical alteration or discontinuation of an established and effective methadone treatment plan, as observed in the plaintiff's case, constitutes substandard care. This approach predictably leads to relapse, overdose, and fatalities. Medical organizations assert that such a standardized, non-MAT protocol does not align with contemporary medical science or acceptable professional standards, and therefore should not be upheld. They advocate for the court to mandate the continuation of the plaintiff's methadone maintenance treatment throughout their brief period of incarceration.

Summary

Leading medical and addiction-medicine organizations, collectively known as Amici, maintain that Opioid Use Disorder (OUD) is a chronic brain disease. They assert that Medication-Assisted Treatment (MAT), especially agonist maintenance with methadone or buprenorphine, represents the evidence-based standard of care, significantly reducing both relapse and mortality rates. Conversely, approaches that focus solely on "detoxification" or withdrawal are viewed as outdated, unsafe, and ineffective; research indicates that relapse rates for such methods frequently exceed 90%, often within a week, and forced withdrawal lowers an individual's tolerance, thereby heightening the risk of overdose. The jail's current policy—which terminates any ongoing MAT upon admission, provides no MAT during the withdrawal phase, and offers at most a single naltrexone injection before release—disregards established clinical judgment, fails to provide individualized care, and substitutes an inferior treatment regimen that lacks support in medical literature. Given that patients respond differently to methadone, buprenorphine, and naltrexone, the nonclinical cessation or substitution of a proven, effective methadone plan, as was the case for the plaintiff, delivers substandard care and predictably leads to relapse, overdose, and death. Amici argue that such a uniform, non-MAT protocol does not align with modern medical science or acceptable professional standards, and thus should not be afforded deference. They urge the Court to order the continuation of the plaintiff’s methadone maintenance treatment for the duration of his short incarceration.

Summary

Leading medical and addiction organizations, known as Amici, explain that Opioid Use Disorder (OUD) is a chronic brain disease. They state that the accepted and evidence-based treatment standard is Medication-Assisted Treatment (MAT), especially with medications like methadone or buprenorphine. These treatments significantly reduce the likelihood of relapse and death.

In contrast, "detox" or withdrawal-only methods are considered outdated, unsafe, and ineffective. Studies show that over 90% of individuals relapse, often within a week, when using these methods. Forced withdrawal also lowers a person's tolerance to opioids, greatly increasing the risk of an overdose.

The jail's policy involves stopping any existing MAT for inmates upon their arrival. It does not provide MAT during withdrawal and only offers a single naltrexone injection before release. This approach ignores professional medical judgment, fails to offer personalized care, and replaces effective treatment with a less supported method. Because individuals respond differently to medications such as methadone, buprenorphine, and naltrexone, stopping or changing an effective methadone plan (like the one the plaintiff was on) without medical reason is considered substandard care. Such actions can predictably lead to relapse, overdose, and death.

Amici argue that this one-size-fits-all, non-MAT protocol does not meet "modern medical science" or "prudent professional standards" and therefore should not be upheld. They are asking the Court to order that the plaintiff's methadone treatment continue during his short time in jail.

Summary

Medical groups that help people with addiction say that opioid addiction is a lasting problem with the brain. They state that the best way to treat it is with medicine-based help, like methadone or buprenorphine. These medicines greatly lower the chance of a person using drugs again and dying.

Just stopping drugs, often called "detox," is an old method that is not safe and does not work well. Studies show that more than 9 out of 10 people use drugs again, often in just one week. Stopping drugs suddenly also makes the body less used to them, which makes overdose more likely.

The jail's rules are to stop any addiction medicine a person is taking when they come in. It does not give any medicine during withdrawal. It might give one shot of naltrexone before a person leaves. This way of doing things does not follow what doctors know is best. It also does not treat each person based on their own needs. This plan is worse and is not supported by studies.

People react differently to medicines like methadone, buprenorphine, and naltrexone. When non-doctors stop a methadone plan that works, like for the person in this case, it is not good care. This can likely cause the person to use drugs again, overdose, or die. The medical groups say this single plan for everyone, which does not use medicine, is not how modern doctors treat people. They ask the Court to make sure the person can keep taking methadone while in jail.