Ramos v. Lamm

This case was an appeal by the State of Colorado (“Colorado”) and Colorado prison officials, challenging an order from the Colorado Federal District Court directing the State of Colorado to close the maximum security unit of the Colorado State Penitentiary at Canon City (“Old Max”).

Inmate Fidel Ramos filed a complaint alleging that the conditions at Old Max violated the inmates’ constitutional protection from cruel and unusual punishment under the Eighth Amendment. The Eight Amendment claims focused on evidence of inadequate shelter and sanitation, poor food service conditions, failure to protect inmates’ personal safety, and inadequate health care. The complaint also cited violations of the First and Fourteenth Amendments relating to the penitentiary’s restrictions on visitations, restriction of prisoners’ mail, and the poor state of the law libraries at Old Max.

The district court certified the suit as a class action, found numerous violations of the plaintiffs’ constitutional rights under the First, Eighth, and Fourteenth Amendments (guaranteeing freedom of speech, freedom from cruel and unusual punishment and due process of law, respectively) and ordered the closure of Old Max.

Colorado appealed the decision, arguing that the district court had erred in its ruling: “(1) in refusing to abstain from exercising its jurisdiction in this case; (2) in failing to ‘apply the correct constitutional standard in making its findings that the totality of conditions at . . . [Old Max] violated the plaintiff class’ eighth amendment rights;’ (3) in finding a constitutional violation because the evidence, measured under the correct constitutional standard, was insufficient to support such findings; and (4) in choosing an appropriate remedy”.  [Page 563]

The Court found that the federal district court was justified in denying the Colorado’s motions to dismiss (contrary to Colorado’s argument that the issues should be dealt with on a state and not federal level),  based on the allegations that the inmates’ constitutional rights had been violated and that abstention was therefore inappropriate due to the federal courts’ duty “to guard, enforce, and protect every right granted or secured by the Constitution of the United States”. [Page 565]

Regarding the Eighth Amendment claims, the Court rejected Colorado’s objection to the constitutional standard applied by the trial court. The district court had applied the “degeneration standard”, entitling an inmate be “confined in an environment which does not result in his degeneration or which threatens his mental and physical well being.” [Page 566]. The Court found that there was actually no conflict between the degeneration standard and the standard proposed by Colorado.

The Court reviewed in detail the evidence presented on the inadequate state of shelter, sanitation, food, personal safety, and medical care in the prison and supported the trial judge’s finding that Old Max’s conditions in these areas violated inmates’ constitutional guarantee of freedom from cruel and unusual punishment.

The Court affirmed the finding that certain prison mail censorship rules (namely, refusal to deliver mail in a language other than English, refusal to deliver mail that would cause a severe psychiatric disturbance to an inmate without a qualified psychiatrist on staff to confirm likelihood of such disturbance, opening of legal mail outside of the presence of the sender) violated the First and Fourteenth Amendments.  The Court also upheld the district court’s finding that the prison’s law libraries were inadequate and that no sufficient alternative means of accessing legal information was furnished, violating inmates’ constitutional right of access to the courts. However, noting that (a) where prisons restrict prisoners’ constitutional rights, such restrictions must comport with legitimate security, order and rehabilitation objectives and (b) the wide deference owed to prison officials in determining which practices are necessary to preserve security, the Court vacated the district court’s finding that prison visitation policies were “overbroad” and not necessary to any “legitimate penological purpose.” The Court found that these visitation policies were a reasonable response to legitimate penal concerns of security.

The district court’s remedial order was vacated in part and the case was remanded for further proceedings in the district court. The Court specified that when fashioning a proper remedy the district court should consider the status and progress of new prison facilities being constructed, Colorado’s specific plans for transfer and housing of inmates in the new facility, as well as the Colorado’s commitment to address deficiencies in personnel.

“(A) policy of judicial restraint cannot encompass any failure to take cognizance of valid constitutional claims whether arising in a federal or state institution. When a prison regulation or practice offends a fundamental constitutional guarantee, federal courts, will discharge their duty to protect constitutional rights.”Page 565

“We yet like to believe that whenever the Federal Courts sit, human rights, under the Federal Constitution are always a proper subject for adjudication, and that we have not the right to decline the exercise of that jurisdiction simply because the rights asserted may be adjudicated in some other forum” Page 565, citing Stapelton v. Mitchell, 60 F.Supp. 51, 55 (D.Kan.).

"…The Supreme Court has not wavered in its holding that the Eighth Amendment . . . is, inter alia, intended to protect and safeguard a prison inmate from an environment where degeneration is probable and self-improvement unlikely because of the conditions existing which inflict needless suffering, whether physical or mental." Page 566, citing Battle v. Anderson, 564 F.2d 388, 393 (10th Cir. 1977).

“This decision should be accorded deference so long as it is a reasonable response to the legitimate concerns of prison security. The existence of less restrictive alternatives is not dispositive of the matter,…for we are convinced that the discretion of prison officials in these matters should stand unless patently unreasonable.” Page 580