Brown v. Plata

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2011 United States Supreme Court case

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

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Coleman v. Brown

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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

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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

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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 , 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 28 U.S.C.  § 2284 .

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](https://en.wikipedia.org/wiki/Kimberly_J._Mu

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