Brown v. Plata

Brief Fact Summary.

Plaintiffs filed a class action lawsuit against Defendant, alleging that California prisons violated the Eighth Amendment to the Constitution, which banned cruel and unusual punishment. Following a lengthy trial, a special panel of three federal judges determined that serious overcrowding in California’s 33 prisons was the primary cause for violations of the Eighth Amendment. The court ordered the release of enough prisoners so the inmate population would come within 137.5 percent of the prisons’ total design capacity. California appealed. U.S. Supreme Court granted cert.

Synopsis of Rule of Law.

A court may impose limits on the overcrowding of prisons to remedy a violation of prisoners’ Eighth Amendment rights.

Facts.

Severe overcrowding of California’s prisons, together with deficient mental health and medical care and lack of state resources, led to the filing of two class actions. The first, Coleman v. Brown, involved prisoners with serious mental disorders. In Coleman, a district court found “overwhelming evidence of the systematic failure to deliver necessary care” to inmates. The second case, Brown v. Plata, involved a class of prisoners with serious medical conditions. In that case, the State conceded that deficiencies in prisons violated the Eighth Amendment’s prohibition against cruel and unusual punishments. The court also found that the California “prison medical care system is broken beyond repair,” resulting in an “unconscionable degree of suffering and death.” The Coleman and Plata plaintiffs moved their respective district courts to convene a three-judge court empowered under the Prison Litigation Reform Act of 1995 (PRLA) to order reductions in the prison population. After extensive testimony and evidence, the three-judge court ordered California to submit a plan to reduce its prison population to 137.5 percent of the prisons’ design capacity within two years which would result in the release of 38,000 to 46,000 inmates. California appealed. The U.S. Supreme Court granted certiorari to review.

Issue.

May a court impose limits on the overcrowding of prisons to remedy a violation of prisoners’ Eighth Amendment rights?

Held.

Yes. The court affirmed the lower court’s decision, because all three factors were satisfied and a court may impose limits on the overcrowding of prisons to remedy a violation of prisoners’ Eighth Amendment rights.

Dissent.

Justice Scalia & Thomas

They criticized the majority for affirming “what is perhaps the most radical injunction issued by a court in our Nation’s history: an order requiring California to release the staggering number of 46,000 convicted criminals.” Justices Scalia and Thomas noted that the three-judge district court’s order violated the terms of the PLRA, ignored limitations on the power of Article III judges, and overstepped federal courts’ institutional capacity. Additionally, letting a class of plaintiffs having suffered an Eighth Amendment violation contradicts the foundational rule that an individual alone must have suffered the violation. Even if plaintiffs claimed they individually suffered a violation and merely aggregated the claims, case law did not support allowing such act.

Discussion.

A court may impose limits on the overcrowding of prisons to remedy a violation of prisoners’ Eighth Amendment rights. Because prisoners are dependent upon a state for food, clothing, and necessary medical care, State’s failure to provide necessities may constitutionally violate the prisoners’ rights. Court may remedy the constitutional violation through various methods, which include reducing a prison’s population. Enacted by Congress, the PLRA restricts a court’s ability to reduce a prison population in some respects. To issue an order limiting the prison population, the three-judge court must find by clear and convincing evidence that: (1) overcrowding is the primary cause of the deprivation of a federal right; (2) no other relief will remedy the violation; (3) the relief must extend no further than necessary to correct the violation. Additionally, when determining whether the three factors are present, the court shall give substantial weight to any adverse impact on public safety or the operation of the criminal justice system caused by the relief. 18 U.S.C. § 3626. While the court is not obligated to guarantee the public safety, it must take measures that will allow state officials to make practical public safety enhancement decisions.

Here, all three factors are present. First, it was clear that overcrowding of the state’s prisons was the “primary cause” of the Eighth Amendment violation. Second, without a reduction in overcrowding, there will be no remedy for those who are physically and/or mentally ill and yet not provided medical care. However, the state’s legislature were either unwilling or unable to find the financial resources necessary to remedy the problem for 16 years. Therefore, no other relief besides a court order will remedy the violation. Lastly, the order did not extend beyond what is necessary to correct the violation. In fact, the order allowed the state to provide a flexible plan that may include the construction of new prison facilities, the transfer of prisoners, and other alternatives to releasing the prisoners. Additionally, it also gave the state a substantial flexibility to determine who should be released within prison population not limited to the mentally ill or medically ill. The court noted that the three-judge court also devoted significant time and gave substantial weight to determining whether there would be any potential adverse impact on public safety. For these reasons, the court affirmed the lower court’s decision.