Brown v. Plata

This case involved an appeal from a decision made by a three-judge court that was convened by the Federal District Court to decide the appropriate remedy for violations of the Eighth Amendment to the United States Constitution. The violations were the subject of two related Federal District Court cases in California: Coleman v. Brown (1990) and Plata v. Brown (2001).

At the Federal District Court level,  both cases had been brought on behalf of plaintiffs that had suffered ongoing violations of their rights in the California prison system. Coleman involved the class of seriously mentally ill persons in California prisons, and Plata involved persons with serious medical conditions in California prisons. The Plaintiffs argued that the medical and mental health care treatment afforded prisoners in California prisons fell short of constitutional requirements, and did not meet the prisoners’ basic health needs. The Federal District Court found that the health care and mental health treatment of the prisoners violated their Eight Amendment rights and ordered a remedial injunction, which California did not comply with. In response, the Federal District Court appointed officials to oversee the reform process. Officials appointed by the Federal District Court in Plata and Coleman evaluated California’s prison health care system, and presented their testimony to the three-judge court.

In 1995 Congress enacted the Prison Litigation Reform Act (PRLA) to regulate how states should remedy serious constitutional violations in their prison system. The PLRA required that the relief granted to remedy such violations be narrowly drawn, extend no further than necessary to remedy the violation, and be the least intrusive means necessary. The Act also requires that the court give substantial weight to any negative impact on public safety that its order may have. The PLRA authorizes the convening of a three-judge court in cases in which reduction of a prison’s population is necessary.

Taking the requirements of the PLRA into consideration, the three-judge court agreed with the Special Master and Receiver appointed in Coleman and Plata that overcrowding was the primary cause of the constitutional violations occurring in California’s prison system. The court considered expert testimony and recommendations by the Special Master and the Receiver when deciding the appropriate remedy for the systemic violations of the prisoners’ rights to adequate mental health and medical services. The three-judge court ordered California prisons to reduce their prison populations to 137.5% of design capacity within two years. The court’s mandate required the release or relocation of an estimated 46,000 prisoners. The State appealed the three-judge court’s decision to the Supreme Court and brought the current action.

The U.S. Supreme Court affirmed the three-judge court’s mandate and ruled that the PLRA allows for the remedy prescribed by the three-judge court.

The Court agreed with the three-judge court’s ruling that overcrowding was the primary cause of constitutional violations in California prisons, and that a prison release order was the only way to substantially reduce the constitutional violation. The Court agreed with the three-judge court that other remedies would be insufficient without reducing overcrowding in California’s prisons. The state had attempted to remedy the situation in the past, but had failed to comply with the conditions outlined by the Coleman and Plata Courts and the violations were ongoing.

The Court ruled, as the three-judge court concluded, that the possible negative effects the release order may have on public safety were outweighed by the need to reform the California prison system so as to remedy the ongoing constitutional violations. The Court stated that the prison release order, by virtue of making prisoners better off, might in fact improve public safety.

The Court suggested that the state should take steps to design a system to determine which prisoners would pose the least threat to public safety if released early. If, in creating such a system and beginning the process of releasing prisoners, the state were to find that it needed five years, rather than two, to reduce its average prison population to 137.5% of capacity, it should file a motion with the district court asking the court to reconsider the requirements of the order.

“A prison that deprives prisoners of adequate medical care, is incompatible with the concept of human dignity and has no place in civilized society.”

“The order in this case does not necessarily require the state to release any prisoners. The state may comply by raising the design capacity of its prisons or by transferring prisoners to county facilities in other States. Because the order limits the prison population as a percentage of design capacity, it nonetheless has the ‘effect of reducing or limiting prison population.’”