Brown v. Plata

What’s at stake? 
Reducing prison overcrowding so severe that it results in unconstitutional health conditions. 

Issue:
Whether a population cap is a justified means of alleviating unconstitutionally unhealthy prison conditions.   

Decision date:
May 23, 2011

Outcome:
5-4 in favor of Plata.  Justice Kennedy delivered the opinion, joined by Justices Ginsburg, Breyer, Sotomayor, and Kagan.  Justice Scalia dissented, joined by Justice Thomas.  Justice Alito dissented, joined by Chief Justice Roberts. 

What the court held:
California prisons currently house twice as many inmates as the prisons were designed to house. As a result of overcrowding, the prisons are incapable of providing basic health care. Prisoners suffering from mental illnesses and those suffering from physical ailments brought separate class action lawsuits to address this problem. The district courts ruled in both cases that California’s inadequate health care facilities violated the Eight Amendment’s prohibition against cruel and unusual punishment and appointed supervisors to oversee a process to remedy the conditions.

Twelve years after one decision and three years after the other, both court-appointed supervisors determined that no progress had been made in remedying the dangerous and unhealthy conditions. The plaintiffs then moved their respective district courts to convene a three-judge court in accordance with the Prison Litigation Reform Act to reduce the prison population. The three-judge court consolidated the two cases and ruled that California must reduce its prison population to 137.5% of design capacity within two years to bring health conditions up to constitutionally acceptable standards.

The Supreme Court upheld the order of the three-judge district court. The Court detailed how the overcrowding has caused mentally and physically ill prisoners to suffer to the point that it violates the Constitution and threatens the safety of prison guards and staff. In his majority opinion, Justice Kennedy wrote that overcrowding “has overtaken the limited resources of prison staff; imposed demands well beyond the capacity of medical and mental health facilities; and created unsanitary and unsafe conditions that make progress in the provision of care difficult or impossible to achieve.”

The Court described how overcrowding denies prisoners minimal mental health care.

Because of a shortage of treatment beds, suicidal inmates may be held for prolonged periods in telephone-booth sized cages without toilets. A psychiatric expert reported observing an inmate who had been held in such a cage for nearly 24 hours, standing in a pool of his own urine, unresponsive and nearly catatonic. Prison officials explained that they had “no place to put him.”

Noting that, in one prison, “up to 50 sick inmates may be held together in a 12- by 20-foot cage for up to five hours awaiting treatment,” and, according to the district court’s extensive factfinding, one inmate needlessly dies in a California prison every week due to deficiencies in health care, the Court concluded that prisoners with physical illnesses receive “severely deficient” treatment.

The Court also rebutted concerns that the panel’s order would threaten public safety. The opinion quoted the former warden of San Quentin and acting secretary of the California prison system stating that the current system “make[s] people worse, and that we are not meeting public safety by the way we treat people.” The Court also relied on the head of Pennsylvania’s correctional system, an expert witness in the case, who stated that measures to reduce prison population may “actually improve on public safety because they address the problems that brought people to jail.” Other expert witnesses “produced statistical evidence that prison populations had been lowered without adversely affecting public safety” in several different jurisdictions, the Court stated.

The majority concluded that the order to reduce California’s prison population would uphold constitutional protections while protecting public safety. “A prison that deprives prisoners of basic sustenance, including adequate medical care, is incompatible with the concept of human dignity and has no place in civilized society,” Justice Kennedy wrote for the Court. Chief Justice Roberts and Justices Scalia, Thomas and Alito dissented.

Learn more:

Merit briefs:

• Intervenors' Opening Brief
• Brief of Appellant Governor Arnold Schwarzenegger
• Brief of Appellee Marciano Plata, et al.
• Brief of Appellee Ralph Coleman, et al.
• Intervenors' Opening Brief
• Brief of Appellee Intervenor California Correctional Peace Officers Association
• Intervenors Response

Amicus briefs:

• Brief for Greater Stockton Chamber of Commerce in Support of Appellant
• Brief for the Criminal Justice Legal Foundation in Support of Appellant
• Brief for the States of Louisiana, Alabama, Alaska, Arkansas, Colorado, Delaware, Illinois, Massachusetts, Michigan, Mississippi, New Mexico, Ohio, Oklahoma, Pennsylvania, South Carolina, Tennessee, Texas, and Virginia in Support of Appellant
• Brief for the American Bar Association in Support of Appellees and Correctional Officer Intervenors
• Brief for the Center on the Administration of Criminal Law and 30 Criminologists in Support of Appellees
• Brief for the American Public Health Association, American Nurses Association, American Association of Public Health Physicians, Academy of Correctional Health Professionals, and the Society of Correctional Physicians in Support of Appellees
• Brief for the American Psychiatric Association, California Psychiatric Association, American Psychological Association, California Psychological Association, American Academy of Psychiatry And The Law, Judge David L. Bazelon Center for Mental Health Law, Forensic Mental Health Association of California, National Alliance On Mental Illness, and NAMI-California in Support of Appellees
• Brief for Corrections and Law Enforcement Personnel in Support of Appellees
• Motion for Leave to File Out of Time Amicus Curiae Brief and Brief for J. Clark Kelso, Receiver for Medical Healthcare for the California State Prisons in Support of Neither Party
• Brief for the American Civil Liberties Union, Human Rights Watch, The Leadership Conference on Civil and Human Rights, and Penal Reform International/The Americans in Support of Affirmance
• Brief for Prison Fellowship, Aleph Institute, American Friends Service Committee, California Council of Churches, Friends Committee on Legislation of California, General Synod of the United Church of Christ, Islamic Shura Council of Southern California, Leadership Conference of Women Religious, National Association of Evangelicals, National Council of Churches, Paulist National Catholic Evangelization Association, Progressive Jewish Alliance, Sojourners, Union for Reform Judaism, and Unitarian Universalist Association in Support of Appellees