563 U.S. 493 (2011), 09-1233, Brown v. Plata
|Citation:||563 U.S. 493, 131 S.Ct. 1910, 179 L.Ed.2d 969, 79 U.S.L.W. 4320, 22 Fla.L.Weekly Fed. S 995|
|Opinion Judge:||Kennedy, Justice.|
|Party Name:||EDMUND G. BROWN, Jr., GOVERNOR OF CALIFORNIA, et al., APPELLANTS v. MARCIANO PLATA et al.|
|Attorney:||Carter G. Phillips, Washington, DC, for appellants. Donald Specter, Berkeley, CA, for appellees. Rod Pacheco, District Attorney, County of Riverside, William E. Mitchell, Assistant District Attorney, Alan D. Tate, Senior Deputy District Attorney, Riverside, CA, for Appellants District Attorney In...|
|Judge Panel:||KENNEDY, J., delivered the opinion of the Court, in which GINSBURG, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. SCALIA, J., filed a dissenting opinion, in which THOMAS, J., joined, post, p. 550. Alito, J., filed a dissenting opinion, in which ROBERTS, C. J., joined, post, p.565. Justice SCALIA, wi...|
|Case Date:||May 23, 2011|
|Court:||United States Supreme Court|
Argued November 30, 2010.
APPEAL FROM THE UNITED STATES DISTRICT COURTS FOR THE EASTERN AND NORTHERN DISTRICTS OF CALIFORNIA No. 09-1233.
[131 S.Ct. 1917] Syllabus [*]
California's prisons are designed to house a population just under 80, 000, but at the time of the decision under review the population was almost double that. The resulting conditions are the subject of two federal class actions. In Coleman v. Brown, filed in 1990, the District Court found that prisoners with serious mental illness do not receive minimal, adequate care. A Special Master appointed to oversee remedial efforts reported 12 years later that the state of mental health care in California's prisons was deteriorating due to increased overcrowding. In Plata v. Brown, filed in 2001, the State conceded that deficiencies in prison medical care violated prisoners' Eighth Amendment rights and stipulated to a remedial injunction. But when the State had not complied with the injunction by 2005, the court appointed a Receiver to oversee remedial efforts. Three years later, the Receiver described continuing deficiencies caused by overcrowding. Believing that a remedy for unconstitutional medical and mental health care could not be achieved without reducing overcrowding, the Coleman and Plata plaintiffs moved their respective District Courts to convene a three-judge court empowered by the Prison Litigation Reform Act of 1995 (PLRA) to order reductions in the prison population. The judges in both actions granted the request, and the cases were consolidated before a single three-judge court. After hearing testimony and making extensive findings of fact, the court ordered California to reduce its prison population to 137.5% of design capacity within two years. Finding that the prison population would have to be reduced if capacity could not be increased through new construction, the court ordered the State to formulate a compliance plan and submit it for court approval.
1. The court-mandated population limit is necessary to remedy the violation [131 S.Ct. 1918] of prisoners' constitutional rights and is authorized by the PLRA. Pp. 1928 -1945.
(a) If a prison deprives prisoners of basic sustenance, including adequate medical care, the courts have a responsibility to remedy the resulting Eighth Amendment violation. See Hutto v. Finney, 437 U.S. 678, 687, n. 9, 98 S.Ct. 2565, 57 L.Ed.2d 522. They must consider a range of options, including the appointment of special masters or receivers, the possibility of consent decrees, and orders limiting a prison's population. Under the PLRA, only a three-judge court may limit a prison population. 18 U.S.C. §3626(a)(3). Before convening such a court, a district court must have entered an order for less intrusive relief that failed to remedy the constitutional violation and must have given the defendant a reasonable time to comply with its prior orders. §3626(a)(3)(A). Once convened, the three-judge court must find by clear and convincing evidence that "crowding is the primary cause of the violation" and "no other relief will remedy [the] violation, " §3626(a)(3)(E); and that the relief is "narrowly drawn, extends no further than necessary. . ., and is the least intrusive means necessary to correct the violation, " §3626(a)(1)(A). The court must give "substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the relief." Ibid. Its legal determinations are reviewed de novo, but its factual findings are reviewed for clear error. Pp. 1928 -1930.
(b) The Coleman and Plata courts acted reasonably in convening a three-judge court. Pp. 1930 -1932.
(1) The merits of the decision to convene are properly before this Court, which has exercised its 28 U.S.C. §1253 jurisdiction to determine the authority of a court below, including whether a three-judge court was properly constituted. Gonzalez v. Automatic Employees Credit Union, 419 U.S. 90, 95, n. 12, 95 S.Ct. 289, 42 L.Ed.2d 249. P. 1930.
(2) Section 3626(a)(3)(A)(i)'s previous order requirement was satisfied in Coleman by the Special Master's 1995 appointment and in Plata by the 2002 approval of a consent decree and stipulated injunction. Both orders were intended to remedy constitutional violations and were given ample time to succeed12 years in Coleman, and 5 years in Plata. Contrary to the State's claim, §3626(a)(3)(A)(ii)'s reasonable time requirement did not require the District Courts to give more time for subsequent remedial efforts to succeed. Such a reading would in effect require courts to impose a moratorium on new remedial orders before issuing a population limit, which would delay an eventual remedy, prolong the courts' involvement, and serve neither the State nor the prisoners. The Coleman and Plata courts had a solid basis to doubt that additional efforts to build new facilities and hire new staff would achieve a remedy, given the ongoing deficiencies recently reported by both the Special Master and the Receiver. Pp. 1930 -1932.
(c) The three-judge court did not err in finding that "crowding [was] the primary cause of the violation, " §3626(a)(3)(E)(i). Pp. 1931 -1937.
(1)The trial record documents the severe impact of burgeoning demand on the provision of care. The evidence showed that there were high vacancy rates for medical and mental health staff, e.g., 20% for surgeons and 54.1% for psychiatrists; that these numbers understated the severity of the crisis because the State has not budgeted sufficient staff to meet demand; and that even if vacant positions could be filled, there would be insufficient space for the additional staff. Such a shortfall contributes to significant delays in treating mentally ill prisoners, who are housed in [131 S.Ct. 1919] administrative segregation for extended periods while awaiting transfer to scarce mental health treatment beds. There are also backlogs of up to 700 prisoners waiting to see a doctor for physical care. Crowding creates unsafe and unsanitary conditions that hamper effective delivery of medical and mental health care. It also promotes unrest and violence and can cause prisoners with latent mental illnesses to worsen and develop overt symptoms. Increased violence requires increased reliance on lockdowns to keep order, and lockdowns further impede the effective delivery of care. Overcrowding's effects are particularly acute in prison reception centers, which process 140,000 new or returning prisoners annually, and which house some prisoners for their entire incarceration period. Numerous experts testified that crowding is the primary cause of the constitutional violations. Pp. 1931 -1935.
(2) Contrary to the State's claim, the three-judge court properly admitted, cited, and considered evidence of current prison conditions as relevant to the issues before it. Expert witnesses based their conclusions on recent observations of prison conditions; the court admitted recent reports on prison conditions by the Receiver and Special Master; and both parties presented testimony related to current conditions. The court's orders cutting off discovery a few months before trial and excluding evidence not pertinent to the issue whether a population limit is appropriate under the PLRA were within the court's sound discretion. Orderly trial management may require discovery deadlines and a clean distinction between litigation of the merits and the remedy. The State points to no significant evidence that it was unable to present and that would have changed the outcome here. Pp. 1934 -1935.
(3) It was permissible for the three-judge court to conclude that overcrowding was the "primary, " but not the only, cause of the violations, and that reducing crowding would not entirely cure the violations. This understanding of the primary cause requirement is consistent with the PLRA. Had Congress intended to require that crowding be the only cause, the PLRA would have said so. Pp. 1935 - 1937.
(d) The evidence supports the three-judge court's finding that "no other relief [would] remedy the violation, " §3626(a)(3)(E)(ii). The State's claim that out-of-state transfers provide a less restrictive alternative to a population limit must fail because requiring transfers is a population limit under the PLRA. Even if they could be regarded as a less restrictive alternative, the three-judge court found no evidence of plans for transfers in numbers sufficient to relieve overcrowding. The court also found no realistic possibility that California could build itself out of this crisis, particularly given the State's ongoing fiscal problems. Further, it rejected additional hiring as a realistic alternative, since the prison system was chronically understaffed and would have insufficient space were adequate personnel retained. The court also did not err when it concluded that, absent a population reduction, the Receiver's and Special Master's continued efforts would not achieve a remedy. Their reports are persuasive evidence that, with no reduction, any remedy might prove unattainable and would at the very least require vast expenditures by the State. The State asserts that these measures would succeed if combined, but a long history of failed remedial orders, together with substantial evidence of overcrowding's deleterious effects on the provision of care, compels a different conclusion here. Pp. 1937 -1939.
(e) The prospective relief ordered here was narrowly drawn, extended no further than necessary to correct the violation [131 S.Ct. 1920] and was the least intrusive means necessary to...
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