Brown v. Plata
|Brown v. Plata|
|Argued November 30, 2010
Decided May 23, 2011
|Full case name||Edmund G. Brown, Jr., Governor of California, et al., Appellants v. Marciano Plata, et al.|
|Prior history||judgment for complainant sub nom. Coleman v. Wilson, 912 F.Supp. 1282 (E.D. Cal., 1995); judgment for complainant sub nom. Plata v. Brown, 3:01-cv-01351-TEH (N.D. Cal.n 2009).|
|Subsequent history||Application for stay denied, 570 U.S. ____ (2013)|
|A court-mandated population limit was necessary to remedy a violation of prisoners' Eighth Amendment constitutional rights.|
|Majority||Kennedy, joined by Ginsburg, Breyer, Sotomayor, Kagan|
|Dissent||Scalia, joined by Thomas|
|Dissent||Alito, joined by Roberts|
|Eighth Amendment to the United States Constitution|
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.
Coleman v. Brown, docket no. 2:90-cv-00520-LKK-JFM (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 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".
Plata v. Brown, docket no. 3:01-cv-01351-TEH (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 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.
In 2006, the plaintiffs in the Coleman and Plata cases filed motions to convene a three-judge court to limit the prison population. 18 U.S.C. § 3626, a statute created by the Violent Crime Control and Law Enforcement Act 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 28 U.S.C. § 2284.
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 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.
California appealed the order to the Supreme Court 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.
According to a national poll of registered voters taken by Fairleigh Dickinson University’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.” 
- 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
- Gullo, Karen (February 10, 2009). "California Must Reduce Inmate Population, U.S. Judges Rule". Bloomberg News. Retrieved October 14, 2009.
- Jurisdictional statement, California Attorney General et. al
- Moore, Solomon (August 4, 2009), California Prisons Must Cut Inmate Population, The New York Times, retrieved 2009-10-13
- Yi, Matthew; Egelko, Bob (September 19, 2009), State fails federal demand to cut prisoners, San Francisco Chronicle, p. C-1, retrieved 2009-10-23
- Egelko, Bob (October 22, 2009), Court, governor dig in heels on prison crowding, San Francisco Chronicle, p. A-11, retrieved 2009-10-23
- Rothfeld, Michael (October 22, 2009), Judges reject California plan to cut prison crowding, Los Angeles Times, p. A-11, retrieved 2009-10-23
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- 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
- Orders in Pending Cases, Monday, June 14, 2010, June 14, 2010
-  , Oyez
- Fairleigh Dickinson University’s PublicMind, (2011, May 23). “U.S. Voters Weigh in on Brown v. Plata, Case involving Prison Overcrowding” [Press Release] May 23, 2011. Retrieved from http://publicmind.fdu.edu/2011/brownvplata/
- Bower, Alicia (2012). "Unconstitutionally Crowded: Brown v. Plata and How the Supreme Court Pushed Back to Keep Prison Reform Litigation Alive". Loyola of Los Angeles Law Review 45 (2): 555–568.
- Page, Joshua (2011). The Toughest Beat : Politics, Punishment, and the Prison Officers' Union in California. New York: Oxford University Press. ISBN 9780195384055.