Brown v. Plata
Encyclopedia
Brown v. Plata was a 2011 decision of the United States Supreme Court holding that a court-mandated population limit was necessary to remedy a violation of prisoners’ Eighth Amendment
constitutional rights. Justice Kennedy filed the majority opinion of the 5 to 4 decision, affirming a decision by a three judge panel of the United States District Court for the Eastern and Northern Districts of California which had ordered California to reduce its prison population to 137.5% of design capacity within two years.
Justice Scalia filed a dissent that was joined by Justice Thomas
and Justice Alito filed a separate dissent that was joined by Chief Justice Roberts.
), is a federal class action
civil rights
lawsuit under the Civil Rights Act of 1871
, Eighth
and Fourteenth Amendment to the United States Constitution
, and the Rehabilitation Act of 1973 alledging unconstitutional mental health care by the California Department of Corrections and Rehabilitation
(CDCR).
The case was filed on April 23, 1990 and was tried before a United States magistrate judge
, and in June 1994 the magistrate judge found that defendants’ delivery of mental health care to class members violated the Eighth Amendment to the United States Constitution
.
On September 13, 1995 the court issued a permanent injunction and ordered that a special master
be appointed to monitor compliance with the court-ordered injunctive relief. The special master submitted 16 interim reports, with later reports "reflect[ing] a troubling reversal in the progress of the remedial efforts of the preceding decade".
), is a federal class action
civil rights
lawsuit alleging that the California Department of Corrections and Rehabilitation
's (CDCR) medical services are inadequate and violate the Eighth Amendment
, the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1973.
The case was filed on April 5, 2001, and re-filed with an amended complaint on August 20, 2001. The alleged deficiencies included inadequate medical screening of incoming prisoners; delays in or failure to provide access to medical care, including specialist care; untimely responses to medical emergencies; the interference of custodial staff with the provision of medical care; the failure to recruit and retain sufficient numbers of competent medical staff; disorganized and incomplete medical records; a "lack of quality control procedures, including lack of physician peer review, quality assurance and death reviews"; a lack of protocols to deal with chronic illnesses, including diabetes, heart disease, hepatitis, and HIV; and the failure of the administrative grievance system to provide timely or adequate responses to complaints concerning medical care. The claims alleged that patients being treated by the CDCR received inadequate medical care that resulted in the deaths of 34 inmate-patients.
The plaintiffs and defendants negotiated a stipulation
for injunctive relief
, which the court approved by court order on June 13, 2002, requiring defendants to provide "only the minimum level of medical care required under the Eighth Amendment."
However, three years after approving the stipulation as an order of the court, the court conducted an evidentiary hearing that revealed the continued existence of appalling conditions arising from defendants’ failure to provide adequate medical care to California inmates. As a result, the court ruled in June 2005 and issued an order on October 3, 2005 putting the CDCR’s medical health care delivery system in receivership
. The receivership became effect in April 2006.
and further amended by the Prison Litigation Reform Act
, sets forth remedies with respect to prison conditions. On October 4, 2006 the Governor
Schwarzenegger
issued Proclamation 4278, declaring a state of emergency
with regard to the prisons. During the pending motions, the Little Hoover Commission
released its report titled "Solving California’s Corrections Crisis: Time Is Running Out" and the CDCR Expert Panel on Adult Offender Recidivism Reduction Programming released its report, both advocating a reduction in prison overcrowding. On July 23, 2007 both the Plata and Coleman courts granted the plaintiff's motions and recommended that the cases be assigned to the same three-judge court. The Chief Judge of the United States Court of Appeals for the Ninth Circuit agreed and, on July 26, 2007, convened the instant three-judge district court pursuant to .
as "scathing", the panel indicated that the state had failed to follow through on previous orders to improve conditions and that the cuts were needed to deal with overcrowding and poor health care that was causing an unnecessary death each week on average. The panel recommended achieving the cuts by reducing imprisonment of nonviolent offenders and technical parole violators.
The state submitted a plan on September 18, 2009 but it the plan failed to meet requirements set by the release order. On October 21, 2009 the court rejected the plan, and gave the government until November 12 to submit a corrected plan or it would order the attorneys for the plaintiff
s to submit a plan and order it implemented. The state submitted a revised plan on November 12, 2009, and the plan was accepted and entered as an order of the court on January 12, 2010.
on January 19, 2010, and the Court postponed jurisdictional questions relating to the appeal on June 14, 2010. It was argued on November 30, 2010.
’s PublicMind in the spring of 2011, just 25% of voters agreed that prisoners would need to be let go if prisons were badly overcrowded and prisoners’ health conditions were poor, while 63% said, “even though conditions are bad, the court cannot order criminals to be released.” Dr. Peter J. Woolley, Director of PublicMind added, “It’s no surprise that the public holds its own interests in much higher regard than health and safety of prisoners or even prison guards”.
Nevertheless, important differences emerged among various segments of the population: men were more sympathetic than women to prisoner release. One in five women (19%) agreed that some prisoners should be released, compared to a third of men (32%). In addition, voters under the age of 30 split on the question of release (42%-43%), while older voters were against allowing courts to order prisoner release by a margin of 2-to1 or more. In terms of ideology, 74% of conservatives were against the idea of court-ordered releases compared to the 48% of liberals. Finally, white voters by 3-to-1 said the courts should not order prisoner releases to remedy overcrowding and health problems, while black voters split on the question, 50%-41%.
Responding to the poll, Bruce Peabody, professor of political science at Fairleigh Dickinson University said the Court’s ruling was “somewhat surprising.” He added “While our current Supreme Court has a mixed record with respect to recognizing various rights of those accused of crimes, it has generally declined to give extensive constitutional protections to those already behind bars… the Court has gone against the wishes of eighteen states who asked for more deference on the issue, and [as a result] it has extended rights to a group – prisoners- who have historically not received much judicial protection.”
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
constitutional rights. Justice Kennedy filed the majority opinion of the 5 to 4 decision, affirming a decision by a three judge panel of the United States District Court for the Eastern and Northern Districts of California which had ordered California to reduce its prison population to 137.5% of design capacity within two years.
Justice Scalia filed a dissent that was joined by Justice Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
and Justice Alito filed a separate dissent that was joined by Chief Justice Roberts.
Coleman
Coleman v. Brown, docket no. 2:90-cv-00520-LKK-JFM (E.D. Cal.United States District Court for the Eastern District of California
The U.S. District Court for the Eastern District of California is composed of six divisions.The Bakersfield division has jurisdiction over certain cases in Inyo and Kern counties and on federal lands and National Parks...
), is a federal class action
Class action
In law, a class action, a class suit, or a representative action is a form of lawsuit in which a large group of people collectively bring a claim to court and/or in which a class of defendants is being sued...
civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
lawsuit under the Civil Rights Act of 1871
Civil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
, Eighth
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
and Fourteenth Amendment to the United States Constitution
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
, and the Rehabilitation Act of 1973 alledging unconstitutional mental health care by the California Department of Corrections and Rehabilitation
California Department of Corrections and Rehabilitation
The California Department of Corrections and Rehabilitation is responsible for the operation of the California state prison and parole systems. CDC&R is the second largest law enforcement or police agency in the United States behind the New York City Police Department which employs approximately...
(CDCR).
The case was filed on April 23, 1990 and was tried before a United States magistrate judge
United States magistrate judge
In the United States federal courts, magistrate judges are appointed to assist United States district court judges in the performance of their duties...
, and in June 1994 the magistrate judge found that defendants’ delivery of mental health care to class members violated the Eighth Amendment to the United States Constitution
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
.
On September 13, 1995 the court issued a permanent injunction and ordered that a special master
Special master
In law, a special master is an authority appointed by a judge to make sure that judicial orders are actually followed.In England, at common law, there were "Masters in Chancery," who acted in aid of the Equity Courts. There were also "Masters in Lunacy," who conducted inquiries of the same nature...
be appointed to monitor compliance with the court-ordered injunctive relief. The special master submitted 16 interim reports, with later reports "reflect[ing] a troubling reversal in the progress of the remedial efforts of the preceding decade".
Plata
Plata v. Brown, docket no. 3:01-cv-01351-TEH (N.D. Cal.United States District Court for the Northern District of California
The United States District Court for the Northern District of California is the federal United States district court whose jurisdiction comprises following counties of California: Alameda, Contra Costa, Del Norte, Humboldt, Lake, Marin, Mendocino, Monterey, Napa, San Benito, San Francisco, San...
), is a federal class action
Class action
In law, a class action, a class suit, or a representative action is a form of lawsuit in which a large group of people collectively bring a claim to court and/or in which a class of defendants is being sued...
civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
lawsuit alleging that the California Department of Corrections and Rehabilitation
California Department of Corrections and Rehabilitation
The California Department of Corrections and Rehabilitation is responsible for the operation of the California state prison and parole systems. CDC&R is the second largest law enforcement or police agency in the United States behind the New York City Police Department which employs approximately...
's (CDCR) medical services are inadequate and violate the Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
, the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1973.
The case was filed on April 5, 2001, and re-filed with an amended complaint on August 20, 2001. The alleged deficiencies included inadequate medical screening of incoming prisoners; delays in or failure to provide access to medical care, including specialist care; untimely responses to medical emergencies; the interference of custodial staff with the provision of medical care; the failure to recruit and retain sufficient numbers of competent medical staff; disorganized and incomplete medical records; a "lack of quality control procedures, including lack of physician peer review, quality assurance and death reviews"; a lack of protocols to deal with chronic illnesses, including diabetes, heart disease, hepatitis, and HIV; and the failure of the administrative grievance system to provide timely or adequate responses to complaints concerning medical care. The claims alleged that patients being treated by the CDCR received inadequate medical care that resulted in the deaths of 34 inmate-patients.
The plaintiffs and defendants negotiated a stipulation
Stipulation
In the law of the United States, a stipulation is an agreement made between opposing parties prior to a pending hearing or trial. For example, both parties might stipulate to certain facts, and therefore not have to argue those facts in court. After the stipulation is entered into, it is...
for injunctive relief
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
, which the court approved by court order on June 13, 2002, requiring defendants to provide "only the minimum level of medical care required under the Eighth Amendment."
However, three years after approving the stipulation as an order of the court, the court conducted an evidentiary hearing that revealed the continued existence of appalling conditions arising from defendants’ failure to provide adequate medical care to California inmates. As a result, the court ruled in June 2005 and issued an order on October 3, 2005 putting the CDCR’s medical health care delivery system in receivership
Receivership
In law, receivership is the situation in which an institution or enterprise is being held by a receiver, a person "placed in the custodial responsibility for the property of others, including tangible and intangible assets and rights." The receivership remedy is an equitable remedy that emerged in...
. The receivership became effect in April 2006.
Three-Judge Court
In 2006, the plaintiffs in the Coleman and Plata cases filed motions to convene a three-judge court to limit the prison population. , a statute created by the Violent Crime Control and Law Enforcement ActViolent Crime Control and Law Enforcement Act
The Violent Crime Control and Law Enforcement Act, , , was an act of Congress dealing with crime and law enforcement that became law in 1994. It is the largest crime bill in the history of the US at 356 pages and will provide for 100,000 new police officers, $9.7 billion in funding for prisons and...
and further amended by the Prison Litigation Reform Act
Prison Litigation Reform Act
The Prison Litigation Reform Act is a U.S. federal law that was enacted in 1996. Congress enacted PLRA in response to a significant increase in prisoner litigation in the federal courts; the PLRA was designed to help unclog the court system from this litigation.For the preceding 20 – 30 years,...
, sets forth remedies with respect to prison conditions. On October 4, 2006 the Governor
Governor of California
The Governor of California is the chief executive of the California state government, whose responsibilities include making annual State of the State addresses to the California State Legislature, submitting the budget, and ensuring that state laws are enforced...
Schwarzenegger
Arnold Schwarzenegger
Arnold Alois Schwarzenegger is an Austrian-American former professional bodybuilder, actor, businessman, investor, and politician. Schwarzenegger served as the 38th Governor of California from 2003 until 2011....
issued Proclamation 4278, declaring a state of emergency
State of emergency
A state of emergency is a governmental declaration that may suspend some normal functions of the executive, legislative and judicial powers, alert citizens to change their normal behaviours, or order government agencies to implement emergency preparedness plans. It can also be used as a rationale...
with regard to the prisons. During the pending motions, the Little Hoover Commission
Little Hoover Commission
The California Little Hoover Commission , officially the Milton Marks "Little Hoover" Commission on California State Government Organization and Economy, is an independent California state oversight agency modeled after the Hoover Commission and created in 1962, that investigates state government...
released its report titled "Solving California’s Corrections Crisis: Time Is Running Out" and the CDCR Expert Panel on Adult Offender Recidivism Reduction Programming released its report, both advocating a reduction in prison overcrowding. On July 23, 2007 both the Plata and Coleman courts granted the plaintiff's motions and recommended that the cases be assigned to the same three-judge court. The Chief Judge of the United States Court of Appeals for the Ninth Circuit agreed and, on July 26, 2007, convened the instant three-judge district court pursuant to .
Release Order
On August 4, 2009 the three-judge court ordered that the defendants submit a plan within 45 days detailing "a population reduction plan that will in no more than two years reduce the population of the CDCR’s adult institutions to 137.5% of their combined design capacity." The plan would require California to cut 40,000 inmates out of its prison population of 150,000 when the verdict was issued. In an order described by The New York TimesThe New York Times
The New York Times is an American daily newspaper founded and continuously published in New York City since 1851. The New York Times has won 106 Pulitzer Prizes, the most of any news organization...
as "scathing", the panel indicated that the state had failed to follow through on previous orders to improve conditions and that the cuts were needed to deal with overcrowding and poor health care that was causing an unnecessary death each week on average. The panel recommended achieving the cuts by reducing imprisonment of nonviolent offenders and technical parole violators.
The state submitted a plan on September 18, 2009 but it the plan failed to meet requirements set by the release order. On October 21, 2009 the court rejected the plan, and gave the government until November 12 to submit a corrected plan or it would order the attorneys for the plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s to submit a plan and order it implemented. The state submitted a revised plan on November 12, 2009, and the plan was accepted and entered as an order of the court on January 12, 2010.
Supreme Court
California appealed the order to the Supreme CourtSupreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
on January 19, 2010, and the Court postponed jurisdictional questions relating to the appeal on June 14, 2010. It was argued on November 30, 2010.
Public Opinion
According to a national poll of registered voters taken by Fairleigh Dickinson UniversityFairleigh Dickinson University
Fairleigh Dickinson University is a private university founded as a junior college in 1942. It now has several campuses located in New Jersey, Canada, and the United Kingdom.-Description:...
’s PublicMind in the spring of 2011, just 25% of voters agreed that prisoners would need to be let go if prisons were badly overcrowded and prisoners’ health conditions were poor, while 63% said, “even though conditions are bad, the court cannot order criminals to be released.” Dr. Peter J. Woolley, Director of PublicMind added, “It’s no surprise that the public holds its own interests in much higher regard than health and safety of prisoners or even prison guards”.
Nevertheless, important differences emerged among various segments of the population: men were more sympathetic than women to prisoner release. One in five women (19%) agreed that some prisoners should be released, compared to a third of men (32%). In addition, voters under the age of 30 split on the question of release (42%-43%), while older voters were against allowing courts to order prisoner release by a margin of 2-to1 or more. In terms of ideology, 74% of conservatives were against the idea of court-ordered releases compared to the 48% of liberals. Finally, white voters by 3-to-1 said the courts should not order prisoner releases to remedy overcrowding and health problems, while black voters split on the question, 50%-41%.
Responding to the poll, Bruce Peabody, professor of political science at Fairleigh Dickinson University said the Court’s ruling was “somewhat surprising.” He added “While our current Supreme Court has a mixed record with respect to recognizing various rights of those accused of crimes, it has generally declined to give extensive constitutional protections to those already behind bars… the Court has gone against the wishes of eighteen states who asked for more deference on the issue, and [as a result] it has extended rights to a group – prisoners- who have historically not received much judicial protection.”