Gates v. Collier

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Gates v. Collier
Seal of the United States Court of Appeals for the Fifth Circuit.svg
CourtUnited States Court of Appeals for the Fifth Circuit
Full case nameNazareth Gates et al v. John Collier, Superintendent, Mississippi State Penitentiary, et al
DecidedSeptember 20, 1974
Citation(s)501 F.2d 1291 (1974)
Case history
Prior action(s)349 F. Supp. 881 (N.D. Miss. 1972); 371 F. Supp. 1368 (1973)
Court membership
Judge(s) sittingElbert Tuttle, Griffin Bell, Irving Loeb Goldberg
Case opinions
Laws applied
Eighth Amendment
Prison labor under the Trusty system
The Mississippi State Penitentiary, the correctional facility that was the subject of the lawsuit

Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974),[1] was a landmark case decided in U.S. federal court that brought an end to the Trusty system and the flagrant inmate abuse that accompanied it at Mississippi State Penitentiary (Parchman) in Sunflower County, Mississippi. It was the first case in a body of law developed in the Fifth Circuit Court of Appeals holding that a variety of forms of corporal punishment against prisoners constituted cruel and unusual punishment and a violation of Eighth Amendment rights.[2] This case was also the first broad-scale intervention by a court in the supervision of prison practices.[3]

In Gates v. Collier, the Court of Appeals found certain forms of corporal punishment violate the Eighth Amendment, including “handcuffing inmates to the fence and to cells for long periods of time, ... and forcing inmates to stand, sit or lie on crates, stumps, or otherwise maintain awkward positions for prolonged periods.”[4]


After years of civil rights protests over the conditions at Parchman, including efforts by the Freedom Riders, civil rights lawyer Roy Haber began to systematically collect evidence of the abuse.[5] Represented by Haber, four Parchman inmates brought suit against the prison superintendent in federal district court alleging violation of their civil rights under the United States Constitution by inflicting cruel and unusual punishment.[3]

In 1972 federal judge William C. Keady found in favor of the inmates, writing that Parchman Farm violated modern standards of decency. He ordered an immediate end to all unconstitutional conditions and practices.[6][7] Racial segregation of inmates was abolished, and the trusty system, which allow certain inmates to have power and control over others, was also abolished.[2]

Subsequently other states utilizing the trusty system, such as Arkansas, Alabama, Louisiana and Texas were also forced to abolish it under the Gates v. Collier rulings.

See also[edit]


  1. ^ Gates v. Collier, 501 F.2d 1291 (5th Cir. 1974).
  2. ^ a b "Parchman Farm and the Ordeal of Jim Crow Justice". Archived from the original on 2006-09-01. Retrieved 2006-08-28.
  3. ^ a b "ACLU Parchman Prison". Archived from the original on 2008-03-07. Retrieved 2006-08-29.
  4. ^ "Correction Law Report" (PDF). New York State Commission of Correction. Fall 2002. Retrieved 2007-11-29.[permanent dead link]
  5. ^ Janine Robben (2007). "Lessons from Parchman Farm". Oregon State Bar Bulletin. Oregon State Bar. Retrieved 2007-11-29.
  6. ^ Gates v. Collier, 349 F. Supp. 881 (N.D. Miss. 1972).
  7. ^ Ted Gioia. Work Songs. Oxford University Press. p. 201. Retrieved 2007-12-08.

Further reading[edit]

  • Oshinsky, David M. "Worse Than Slavery: Parchman Farm and the Ordeal of Jim Crow Justice." The Free Press: NY (1996) ISBN 0-684-83095-7.

External links[edit]