LANDMARK CORRECTIONAL CASES

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Bell v Wolfish (1979) – The United States Supreme Court found that it was not a violation of the 4th Amendment to conduct intrusive body searches on pre-trial detainees. It also held that the “double bunking” practice does not deprive pretrial detainees of their liberty without due process of the law. The courts held that the possible innocence of pre-trial detainees should not prevent corrections officials from taking necessary steps to maintain their facility.

This case started with the facility staff in New York double bunking inmates in single occupancy rooms, in which the inmates believed their privacy was being jeopardized. The respondents filed a lawsuit claiming that pre-trial detainees should not be housed and treated in the same manner as sentenced inmates, and challenged the conditions under which pretrial defendants are confined. The petitioners claimed that in the absence of a conviction, subjecting incarcerated defendants automatically to the same conditions as convicted felons was unconstitutional. The federal district court agreed with this view, holding that defendants could only be deprived of liberty as a matter of “compelling necessity”. However, it was also determined by the Supreme Court that the possible innocence of pre-trial detainees should not prevent corrections officials from taking necessary steps to maintain their facility.

Williams v Fitch (2001) – The United States Supreme Court upheld that “Random” pat down searches within an institution are reasonable.

There were 3 incidents alleged by Williams, which were undertaken in a reasonable manner, in a private location, with undue physical intrusion, humiliation or physical injury, and for the purpose of locating contraband. Williams claimed that the searches were physically invasive, but the searches did not rise to being objectively serious enough to raise a constitutional claim.

Estelle v Gamble (1976) – The United States Supreme Court established a standard of what a prisoner must plead in order to claim a violation of the 8th Amendment. The courts decided that an inmate must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs. Gambles complaint of not being provided appropriate care was credited by the courts, however, it did not rise to the level of “cruel and unusual punishment.”

J. W. Gamble was a state prisoner within the Texas Department of Corrections who was given a prison labor assignment loading and unloading cotton bales from a truck. On November 9, 1973, he injured his back when a cotton bale fell on him. Over the next three months, he complained of back and chest pains, was subject to administrative segregation for refusing to work, and ultimately was treated for an irregular heartbeat.

On February 11, 1974, Gamble initiated his lawsuit pro se by submitting a handwritten document to the court. The Court found for the defendant because it viewed his failure to receive proper medical care as “inadvertent”. The case established the principle that the deliberate and failure of prison authorities to address the medical needs of an inmate constitutes “cruel and unusual punishment”. It held that “deliberate indifference” to serious medical needs of prisoners constitutes the “unnecessary and wanton infliction of pain” as proscribed by the Eighth Amendment.

Hudson v McMillian (1992) – The United States Supreme Court decided based on a 7-2 vote that the use of excessive force against a prisoner may constitute “cruel and unusual punishment” even though the inmate does not suffer any serious Injury.

In this case, the Petitioner Hudson, a Louisiana prison inmate, testified that he had suffered minor bruises, facial swelling, loosened teeth, and a cracked dental plate from a beating by prison guards McMillian and Woods, while he was handcuffed and “shackled” following an argument with McMillian. The respondent Mezo, a supervisor on duty, watched the beating, but merely told the officers “not to have too much fun” condoning the unnecessary use of force.

Hudson v Palmer (1984) – The United States Supreme Court decided that officials within a correctional institution do not need probable cause or reasonable suspicion to conduct a cell search, as long as the search is not done solely to harass the inmate. Therefore, the 4th Amendment does not apply to cell searches.

In this case the plaintiff alleged that a guard had conducted a ‘‘shakedown’’ search of his cell to harass him, and ‘‘intentionally destroyed certain items of his non-contraband personal property.’’ The Court ultimately held that “the Fourth Amendment proscription against unreasonable searches does not apply within the confines of the prison cell,’’ reasoning that affording prisoners a privacy right in their cells would defeat effective and safe prison operations.

Wolff v. McDonnel (1974) The United States Supreme Court held that although a prisoners Constitutional rights are diminished upon conviction, and while jails and prisons can and must curtail rights to maintain discipline and control for security and protection of all, not all rights are given up at the prison gate.

A Nebraska inmate in a state prison started a lawsuit, on behalf of himself and other inmates, alleging that prison disciplinary proceedings violated the Due Process Clause of the Fourteenth Amendment. The lawsuit also objected to the prison’s inspection of privileged mail between inmates and their attorneys. The district court rejected the disciplinary proceeding claims, but held that the inspection of mail violated the prisoners’ right of access to the courts. The U.S. Court of Appeals for the Eighth Circuit reversed on the disciplinary proceeding claims, holding that prisons should use the procedures used in probation and parole hearings for disciplinary proceeding. The court also affirmed the district court as to the inspection of mail.

Hughes v Rowe (1980) – The United States Supreme Court held that a district court should not award attorney fees to a prevailing defendant unless the exacting standards in which the complaint is meritless in the sense that it is groundless or without foundation. The courts decided that the Due Process clause of the 14th Amendment affords a prisoner certain minimum procedural safeguards before disciplinary action may be taken. Segregation of a prisoner without a prior hearing may violate Due Process if the postponement of procedural protections is not justified by apprehended emergency conditions.

In this case a state prisoner was placed in a segregation cell for a violation of prison regulations, was given a hearing two days later, and after admitting to the violation, he was sentenced to 10 days segregation. After exhausting administrative remedies, petitioner brought a federal court civil rights action against respondent Illinois corrections officers. The complaint, which was prepared without the assistance of counsel, raised federal questions concerning, inter alia, the initial decision to place petitioner in segregation without a prior hearing. Respondents filed no affidavits denying or explaining the facts alleged by the prisoner. The District Court dismissed the complaint without taking any evidence, and later ordered the prisoner to pay counsel fees for services rendered by the Attorney General of Illinois in representing respondents in the action. The Court of Appeals affirmed.

Lee v Washington (1968) – This case came out of Alabama where they were segregating their jails, juvenile jails and prisons based on race. The United States Supreme Court upheld a decision made by the Court of Appeals, to forbid segregation of public prisons based on race. It was finally decided that Institution authorities have the right, acting in good faith and in particularized circumstances, to take in account racial tensions in maintaining safety, security, discipline and order. This would be the case that ultimately put an end to the “Hands Off Era”.

Turner v Safley (1987) – The United States Supreme Court had to make a decision, which involved the constitutionality of two prison regulations. Both prisoners had different circumstances and distinct claims involved in their case, but it related to the fundamental right to marry. The Courts ruled and upheld a regulation that allowed prison officials to prohibit inmates at one facility from corresponding with inmates at another facility in certain cases. The Courts declined the regulation prohibiting inmates from marrying without the permission of the warden, finding it unreasonable as it impermissibly burdened their right to marry. Marriage is a fundamental right protected by the liberty element of the Due Process clause and the 1st Amendment.

This case was applied with the case O’lone v Estate of Shabazz, a U.S. Supreme Court decision involving the constitutionality of prison regulations. In O’lone v Estate of Shabazz, two inmates who were practicing Muslims were assigned to an outside prison job where they were unable to attend a religious service. The court ruled that it was not a violation of the Free Exercise Clause of the First Amendment to deprive an inmate of attending a religious service for “legitimate penological interests.” These two 1st Amendment cases developed a standard (or test) now used by the courts to balance prisoners’ rights with penological interests.

Kingsley v Hendrickson (2014) – The United States Supreme Court found that in order to prove an excessive force claim, a pre-trial detainee must show that the officers use of that force was objectively unreasonable. He or she does not need to show that the officers were subjectively aware that their use of force was unreasonable. This decision creates a crucial new protection against police abuse. Before Kingsley v. Hendrickson, there was not much clarity on which constitutional protections pre-trial detainees were afforded. As the 8th Amendment applies to convicted prisoners, and the 4th Amendment applies those mistreated by police outside of prisons, Kingsley v. Hendrickson filled in the gray area in dealing with pre-trial detainees. After the decision, any “objectively unreasonable” use of force against pre-trial detainees is seen as unconstitutional, as they cannot be punished at all.

Kingsley was being held in detention at a Monroe County jail in Sparta, Wisconsin in 2010, awaiting trial on drug charges. He was repeatedly ordered by officers to remove a piece of paper he had taped to the overhead light of his cell. In order to remove the paper, Kingsley was ordered to temporarily move to a receiving (holding) cell. Refusing to comply with officers’ commands to stand against the door of his cell to be handcuffed, Kingsley was forcibly removed from the cell by four officers, one of whom was the defendant, Sergeant Stan Hendrickson, and moved to a receiving cell. All parties agreed that in the receiving cell, Sergeant Hendrickson placed his knee in Kingsley’s back and Deputy Sheriff Fritz Degner eventually applied a Taser to his back. However, the officers testified that Kingsley resisted their attempted removal of his handcuffs. Kingsley testified that he had not resisted their attempt and alleged that after being placed in the receiving cell, the officers had slammed his head into a concrete bunk, which the officers denied. After being tased, Kingsley was left handcuffed in the cell for around 15 minutes, after which the officers removed his handcuffs.

Kingsley brought a civil action lawsuit, Kingsley v. Josvai, against Hendrickson and Degner in the U.S. District Court for the Western District of Wisconsin, alleging a use of excessive force by the officers in violation of the Due Process Clause of the Fourteenth Amendment.[2] Judge Barbara Brandriff Crabb denied the officers’ motion for a summary judgment and the case moved to trial. Judge Crabb instructed the jury before deliberation that:

“In deciding whether one or more defendants used ‘unreasonable’ force against plaintiff, you must consider whether it was unreasonable from the perspective of a reasonable officer facing the same circumstances that defendants faced. You must make this decision based on what defendants knew at the time of the incident, not based on what you know now.” The jury found in favor of the officers.

Graham v. Connor (1989) – This was a United States Supreme Court case that determined all excessive force claims by law enforcement officials – deadly or not – in the course of an arrest, investigatory stop, or other “seizure” of a free citizen are properly analyzed under the Fourth Amendment’s “objective reasonableness” standard, rather than under a substantive due process standard.

Petitioner Graham, a diabetic, asked his friend to drive him to a convenience store to purchase orange juice to counteract the onset of an insulin reaction. Upon entering the store and seeing the number of people ahead of him, Graham hurried out and asked Berry to drive him to a friend’s house instead. Respondent Connor, a city police officer, became suspicious after seeing Graham hastily enter and leave the store, followed the car Graham was in and made an investigative stop, ordering both of them to wait while he found out what had happened in the store. Backup police officers arrived on the scene, handcuffed Graham, and ignored or rebuffed attempts to explain and treat Graham’s condition. During the encounter, Graham sustained multiple injuries. He was released when Connor learned that nothing had happened in the store. Graham filed suit in the District Court under 42 U.S.C. 1983 against the respondents, alleging that they had used excessive force in making the stop, in violation of “rights secured to him under the Fourteenth Amendment to the United States Constitution and 42 U.S.C. 1983.” The District Court granted respondents’ motion for a directed verdict at the close of Graham’s evidence, applying a four-factor test for determining when excessive use of force gives rise to a 1983 cause of action, which inquires, inter alia, whether the force was applied in a good-faith effort to maintain and restore discipline or maliciously and sadistically for the very purpose of causing harm. Johnson v. Glick, 481 F.2d 1028. The Court of Appeals affirmed, endorsing this test as generally applicable to all claims of constitutionally excessive force brought against government officials, rejecting Graham’s argument that it was error to require him to prove that the allegedly excessive force was applied maliciously and sadistically to cause harm, and holding that a reasonable jury applying the Johnson v. Glick test to his evidence could not find that the force applied was constitutionally excessive.

Tennessee v. Garner (1985) – The United States Supreme Court held that under the 4th Amendment, when a law enforcement officer is pursuing a fleeing suspect, he or she may not use deadly force to prevent escape unless “the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical injury to the officer or others.” The courts finally decided that unless it is “necessary”, a law enforcement officer may not use deadly force to prevent the escape of a fleeing felon.

At about 10:45 p.m. on October 3, 1974, Memphis police officers Leslie Wright and Elton Hymon were dispatched to answer a burglary call next door. Officer Hymon went behind the house as his partner radioed back to the station. Hymon witnessed someone running across the yard. The fleeing suspect, Edward Garner, stopped at a 6-foot-high (1.8 m) chain-link fence. Using his flashlight, Hymon could see Garner’s face and hands, and was reasonably sure that Garner was unarmed. The police testified that they believed Garner was 17 or 18 years old; Garner was in fact 15 years old. After Hymon ordered Garner to halt, Garner began to climb the fence. Believing that Garner would certainly flee if he made it over the fence, Hymon shot him. The bullet struck Garner in the back of the head, and he died shortly after an ambulance took him to a nearby hospital. Ten dollars and a purse taken from the burglarized house were found on his person.

Hymon acted according to a Tennessee state statute and official Memphis Police Department policy authorizing deadly force against a fleeing suspect. The statute provided that “if, after notice of the intention to arrest the defendant, he either flee or forcibly resist, the officer may use all the necessary means to effect the arrest.”

Garner’s father then brought suit in the United States District Court for the Western District of Tennessee under the Civil Rights Act of 1871, 42 U.S.C. § 1983, naming the City of Memphis, its mayor, the Memphis Police Department, its director, and Officer Hymon as defendants. The District Court found the statute, and Hymon’s actions, to be constitutional. On appeal, the United States Court of Appeals for the Sixth Circuit reversed. The Court of Appeals held that the killing of a fleeing suspect is a “seizure” for the purposes of the Fourth Amendment, and is therefore constitutional only when it is reasonable. The court then found that based on the facts in this case, the Tennessee statute failed to properly limit the use of deadly force by reference to the seriousness of the felony.

Farmer v. Brennan (1994) – This was a case in which the Supreme Court of the United States ruled that a prison official’s deliberate indifference to a substantial risk of serious harm to an inmate violates the cruel and unusual punishment clause of the Eighth Amendment. Prison Officials have a duty under the 8th Amendment to provide humane conditions of confinement.

Dee Farmer, a transgender woman, was incarcerated with the general male population after she was transferred to the US Penitentiary Terre Haute, Indiana. She was repeatedly raped and beaten by the other inmates and acquired HIV as a result. Farmer claimed that the prison administration should have known that she was particularly vulnerable to sexual violence. The case concluded that failure to prevent inmate assaults violates the Eighth Amendment only if prison officials were “reckless in a criminal sense,” meaning the they had “actual knowledge” of a potential danger, and that respondents lacked such knowledge because petitioner never expressed any safety concerns to them. The Court of Appeals affirmed.

Madrid v. Gomez (1996) – This was a case in 1990 where prisoners at the Pelican Bay State Prison in Crescent City, California filed a class action lawsuit against the California Department of Corrections in the U.S. District Court for the Northern District of California. The plaintiffs, represented by the Prison Law Office, alleged that the conditions of their confinement were unconstitutional, and they asked the court for declaratory and injunctive relief. Specifically, the plaintiffs alleged that the defendants unconstitutionally condoned a pattern and practice of using excessive force against inmates, failed to provide inmates with adequate medical and mental health care, imposed inhumane conditions in the Security Housing Unit, utilized cell-assignment procedures that exposed inmates to an unreasonable risk of assault from other inmates, failed to provide adequate procedural safeguards when segregating the prison gang affiliates in the Security Housing Unit, and failed to provide inmates with adequate access to the courts.

 

 

 

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