Holland v. Steele

Brief Fact Summary.

This case involves Holland’s (Plaintiff) Motion for Class Certification of all persons who are or will be detained in the Dade County Jail in Trenton, Georgia in a civil rights action.

Synopsis of Rule of Law.

The requirements of a class action are that the class is so numerous that joinder of all members is impracticable; there are common questions of law or fact; the claims or defenses of the representative parties are typical of the claims or defenses of the class; and the representative parties will fairly and adequately protect the interests of the class.

Facts.

Plaintiffs brought the following civil rights action seeking an order prohibiting Steele (Defendant) from restricting Plaintiffs’ access to counsel and to the civil courts. Plaintiff made a Motion for Class Certification of all persons who are or will be detained in the Dade County Jail. Defendant filed a objection to the assertions in Plaintiffs’ briefs, and contends that class certification of all persons detained at the Dade County Jail would be inappropriate in light of jail population composed of pre-trial detainees and those serving sentences after conviction.

Issue.

Whether Plaintiffs’ Motion for Class Certification should be granted?

Held.

Yes. The prerequisites of a class action are that the class is so numerous that joinder of all members is impracticable; there a common questions of law or fact; the claims or defenses of the representative parties are typical of the claims or defenses of the class; and the representative parties will adequately protect the interests of the class. The court must also find that the party opposing the class has acted or refused to act on grounds generally applicable to the class. The Plaintiffs’ allegations are sufficient to comply with the numerosity requirement, since at least forty inmates and detainees will be housed in the jail in the next year. There are common questions of fact as to the acts, omissions and policies of the Defendant in denying access to counsel to jail inmates. There is also a common question of law raised by the Plaintiff if the practices of the Defendant violate the rights afforded under the Sixth and Fourteenth Amendments of the United States Constitution. The requirement that the represented parties claims be typical of the class does not mean that all claims must be identical. Typicality is found when a class representative is part of the class, possessed the same interest, and suffered the same injury as the class members. Here, Plaintiffs’ claim is typical of the class of inmates denied access to counsel. When determining whether an individual is an adequate representative, the court must look at two factors: the representative must have common interests with the unnamed members of the class, and it must appear that the representative will vigorously prosecute the interests of the class. Here the Plaintiff has common interests with the unnamed members and is represented by a team of attorneys that has experience in class litigation and civil rights. The right to counsel attaches to detainees and sentences alike and appear to present no obstacle to the certification of the class comprise of those detained in Dade County Jail. Therefore, the Defendant has failed to act on grounds that are generally applicable to the class as a whole.

Discussion.

There are three types of class actions. In the first type of class action, a class action is permitted if the prosecution of separate actions would create one of two risks, establishes incompatible standards of conduct for Defendant through inconsistent adjudications or substantially impairs the interests of other members of the class. The second type of class action is appropriate when equitable relief is sought as to rights held in common. The third type of class is for cases with common predominate question of law or fact.