Brown, Governor of California, et al. v. Plata et al.

This case was about California’s prisons which at the time housed 156,000 prisoners, two fold of the number they were designed to house. The plaintiffs previously had brought two separate Federal actions. In 1990, one of the district courts had decided that mentally ill prisoners received inadequate medical care; in 2001, the other district court held that lack of adequate medical care was a violation of prisoners’ 8^th Amendment rights for which it imposed a remedial injunction against the State of California. As the problem continued, the second district court appointed a Receiver who, after three years, found that the cause of the problem was the overcrowdedness in prisons. The cases of the two plaintiffs were consolidated in 2008 in a single three-judge court as provided under the Prison Litigation Reform Act (PLRA). The single three-judge 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.” [Page 1]The single three-judge court held that a restriction on the number of prison population was necessary to address the violation of prisoners’ rights and mandated under PLRA.

The Supreme Court (the court) examined the case as appealed from the single three-judge court’s order. The court noted that the reduction of prison population hadn’t addressed the constitutional violation (the violation of the due process clause of the 14^th Amendment which prohibited cruel and unusual punishments). The issue brought on appeal was whether the order of the single three-judge court was in line with PLRA. The court observed that the order of single three-judge court left it to State Officials to choose the means of reducing the prison population. It also noted that the State had to reduce 46,000 prisoners but was able to reduce only 9,000 at the time of appeal. The constitutional violation had continued for years due to the sub-standard physical and mental health services provided to prisoners. The court also noted that it was impossible to improve the quality of medical care in prisons due mainly to the overcrowding that had resulted in unsafe and unsanitary conditions as well as in imbalance between the healthcare demand and the resources available. The court, therefore, held that the PLRA had mandated the relief granted by the single three-judge court. It also held that the restriction on the number of prison population was necessitated by the violation of prisoners’ constitutional rights. It further noted that the requirements under PLRA of giving a substantial weight to the safety of the public didn’t oblige the single three-judge court to prove the fact that its decision had no negative impact on the public. The court considered the negative impacts (on the public’s safety) of the enforcement of the order if the means the State would use was releasing prisoners. Yet, it noted that the authority to order remedies (such as limits on prison population) for constitutional violations had been given to courts under PLRA. It held that courts were responsible for considering the effects of their rulings on the public’s safety as well as for controlling/mitigating any adverse effects that may have resulted; States do so while addressing the constitutional violation concerned. The court affirmed the order of the single three-judge court while preserving the State’s right to request a modification of the order.

“While the order does in some respects shape or control the State’s authority in the realm of prison administration, it does so in a manner that leaves much to the State’s discretion. The State may choose how to allocate prisoners between institutions; it may choose whether to increase the prisons’ capacity through construction or reduce the population; and, if it does reduce the population, it may decide what steps to take to achieve the necessary reduction. The order’s limited scope is necessary to remedy a constitutional violation.” [Page 42]

“The State’s desire to avoid a population limit, justified as according respect to state authority, creates a certain and unacceptable risk of continuing violations of the rights of sick and mentally ill prisoners, with the result that many more will die or needlessly suffer. The Constitution does not permit this wrong.” [Page 42]