Brown v. Plata, 563 U.S. 493 (2011), was a decision by the Supreme Court of the United States 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. A separate dissent was filed by Justice Alito that was joined by Chief Justice Roberts.
History
Coleman v. Brown
Coleman v. Brown (Previously Coleman v. Wilson) (E.D. Cal.), 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 alleging unconstitutional mental health care by the California Department of Corrections and Rehabilitation (CDCR).
The case was filed on April 23, 1990, and tried before a United States magistrate judge. 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 upheld the magistrate judge's factual findings regarding mental health care screening, insufficient number of staff, incompetence of staff, delays in access to care, medication management and involuntary medication. The court also 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".
Plata v. Brown
Plata v. Brown (N.D. Cal.), 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 plaintiffs claimed a number of deficiencies related to inadequate medical care including, but not limited to: inadequate medical screening of incoming prisoners; delays in or failure to provide access to medical care; untimely responses to medical emergencies; the interference of custodial staff with the provision of medical care; insufficient numbers of competent medical staff; incomplete medical records; a "lack of quality control procedures,"; a lack of protocols to deal with chronic illnesses; 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 inmates.
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.
Plata v. Brown/Coleman v. Brown 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.Order for population reduction plan, three-judge court convened by the Chief Judge of the United States Court of Appeals for the Ninth Circuit hearing Plata v. Schwarzenegger and Coleman v. Schwarzenegger , a statute created by the Violent Crime Control and Law Enforcement Act and further amended by the Prison Litigation Reform Act, requires that any orders for the reduction of prisoner population be issued by a court consisting of three district judges. On October 4, 2006, 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 .
The Three-Judge Court initially consisted of Judge Thelton Henderson, Judge Lawrence Karlton, and Judge Stephen Reinhardt. Judge Karlton passed away and then Judge Kimberly Mueller joined the Three-Judge Court on September 1, 2014. On August 14, 2017 Judge Jon Tigar took the place of Judge Henderson. After Judge Reinhardt's death, Judge Kim Wardlaw took his place on April 4, 2018.ORDER designating and assigning the Honorable Kim McLane Wardlaw, Circuit Judge for the Ninth Circuit Court of Appeals, to take the place of Judge Reinhardt. Signed by Chief Judge Sidney R. Thomas on April 4, 2018. (Filed on 4/4/2018) (Entered: 04/04/2018).
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 decarceration 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 Times 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 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 plaintiffs 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.Order to reduce prison population , three-judge court convened by the Chief Judge of the United States Court of Appeals for the Ninth Circuit hearing Plata v. Schwarzenegger and Coleman v. Schwarzenegger
United States Supreme Court Decision California appealed the order to the Supreme Court on January 19, 2010,Jurisdictional statement, California Attorney General et al. and the Court postponed jurisdictional questions relating to the appeal on June 14, 2010. It was argued on November 30, 2010.
Opinion of the Court A five justice majority of the Court affirmed the prisoner release order. Sacramento native Justice Anthony Kennedy wrote for the Court, first chronicling the troubled 11 years California prisons operated near 200% of design capacity. Kennedy then offers a parade of horribles, including that 54 prisoners may share a single toilet, suicidal prisoners have been locked for nearly 24 hours in telephone booth sized cages, and that a preventable death occurs once every five to six days. Because "prisoners retain the essence of human dignity inherent in all persons", the courts have a responsibility to remedy violations of the Eighth Amendment's prohibition against cruel and unusual punishment.
Kennedy notes that the Prison Litigation Reform Act of 1996 (PLRA) only allows a three-judge court to order a limit on prison population. A three-judge court can only be convened after less intrusive orders have failed and the State has been given a reasonable time to comply with prior orders. Because over 12 years have passed since the initial Coleman order, Kennedy rejects California's argument that it has not been given reasonable time to comply. Kennedy likewise finds less intrusive orders have failed because over 70 orders have already been issued and the Plata Receiver had stated that a solution other than reducing overcrowding would "all but bankrupt the State of California".Brown v. Plata, 131 S. Ct. 1910, 1931 (2011).
The PLRA's requirement that crowding is the primary cause of the violation is met because, according to Kennedy, deference should be given to the three-judge court's findings. Adequate staffing is unfeasible because prisons had a 54% vacancy rate for psychiatrists and they already "would hire any doctor who had ‘a license, a pulse and a pair of shoes’." This quote was taken directly from Dr. Ronald Shansky (the patriarch of correctional healthcare) in his testimony against the California Department of Corrections and Rehabilitation.131 S. Ct. at 1927.Kennedy then catalogs the many ways overcrowding causes problems, noting that orderly trial management requires some deadline to discovery, and that the PLRA merely requires overcrowding to be the primary, not the only, cause of the constitutional violation.
Kennedy rejects California's argument that out of state prison transfers are an available alternative relief to prisoner reductions because out of state transfers are a prisoner reduction under the PLRA. Furthermore, Kennedy rejects the availability of alternative solutions because "California's Legislature has not been willing or able to allocate the resources necessary to meet this crisis".131 S. Ct. at 1939.
The PLRA requires prospective relief to be narrowly drawn, extend no further than is necessary to correct the violation, and be the least intrusive means of correcting the violation. The "positive effect" of releasing healthy prisoners who are not members of the class actions is still narrowly tailored because, according to Kennedy, the scope of the remedy must be proportional to the scope of the violation. Placing a population limit on the entire state prison system instead of the plaintiffs’ prisons is less intrusive because it allows the State flexibility to shift prisoners between prisons. Additionally, Kennedy writes that the prisoner release order is not overbroad because the State will be allowed to ask the three-judge court to modify the order, someday.
Kennedy finds the three-judge court met the PLRA requirement that substantial weight must be given to public safety. The "difficult predictive judgments" prospective relief requires means that courts "can and should" rely on expert testimony.131 S. Ct. at 1942. Noting that there were nearly 10 days of trial on the public safety issue, Kennedy agrees with the three-judge court that releasing criminals from prison "could even improve public safety" because the prisons are making people worse.