American Samoa Government v. Lafoga

Order Denying Motions to Dismiss:

INTRODUCTION

Three prisoners escaped from the Tafuna Correctional Facility ("TCF"), where they had been confined following conviction. On March 25, 1996, Bernard escaped from the prison by walking through the open front gate. He was arrested a few hours later and returned to confinement. Patu and Lafoga walked out the front gate of the TCF on April 2, 1996. Patu returned to the facility later that afternoon. Lafoga was arrested and returned to TCF the next day.

Following their respective returns to custody, all three were removed from the general population and…