Supreme Court Allows Release of Prisoners in California

Brown v. Plata, 131 S.Ct. 1910

The case arose from serious constitutional violations in California’s prison system. The violations existed for years. The appeal came to the Supreme Court from a three-judge District Courtorder directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, binding on the states by the Due Process Clause of the Fourteenth Amendment. The violations were the subject of two class actions in two Federal District Courts. The first, Coleman v. Brown, involved a class of prisoners with serious mental disorders. The second case, Plata v. Brown, involved prisoners with serious medical conditions. The order of the three-judge District Court was applicable to both cases. After years of litigation, it became apparent that a remedy for the constitutional violations would not be effective absent a reduction in the prison system population. The three-judge panel allowed for such a reduction. The Supreme Court held that the Prison Litigation Reform Act of 1995 (PLRA) allowed for the reduction.

At the time this matter went to trial, California’s correctional facility held some 156,000 persons. This was double the amount that California’s prison system was designed to hold. The three-judge panel estimated that the required population reduction could be as high as 46,000 persons. The states had, at one point, reduced the population by 9,000 persons during the pendency of the appeal, creating a further reduction necessary of 37,000 persons. The court noted that the state may employ measures, including good time credits and diversion of low-risk offenders and technical parole violators to community-based programs that will mitigate the order’s impact to reduce the prison population. However, a reduction of the prison population was necessary regardless.

The court held that a reduction of the prison population was necessary because for years the medical and mental health care provided by California’s prisons had fallen short of minimum constitutional requirements and had failed to meet prisoner’s basic health needs. The court noted that there had been needless suffering and deaths as a result. The overcrowding had overtaken the limited resources of prison staff, imposed demands well beyond the capacity of medical and mental health facilities, created unsanitary and unsafe conditions, and made progress in the provision of care difficult or impossible to achieve.