“…The resistance of most judges to implement Recommendation 62 is unsurprising given earlier studies. Other scholars have shown not only that the São Paulo Court of Justice resists granting habeas relief in general (Freitas, 2020), but that lower courts rarely follow higher courts' de-incarceration recommendations (Machado, Barros, Guaranha, & Passos, 2018) 9 . Taking the effects of the pandemic seriously requires acknowledging that, in a context of mass incarceration, mass release is the only solution to the uncontained spread of the virus and the loss of human lives 10 .…”