Law School Case Brief
Bell v. Wolfish - 441 U.S. 520, 99 S. Ct. 1861 (1979)
Prison administrators should be accorded wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security.
Respondent inmates brought this class action in Federal District Court challenging the constitutionality of numerous conditions of confinement and practices in the Metropolitan Correctional Center (MCC), a federally operated short-term custodial facility in New York City designed primarily to house pretrial detainees. The District Court, on various constitutional grounds, enjoined, inter alia, the practice of housing, primarily for sleeping purposes, two inmates in individual rooms originally intended for single occupancy ("double-bunking"); enforcement of the so-called "publisher-only" rule prohibiting inmates from receiving hard-cover books that are not mailed directly from publishers, book clubs, or bookstores; the prohibition against inmates' receipt of packages of food and personal items from outside the institution; the practice of body-cavity searches of inmates following contact visits with persons from outside the institution; and the requirement that pretrial detainees remain outside their rooms during routine inspections by MCC officials. The Court of Appeals affirmed these rulings, holding with respect to the "double-bunking" practice that the MCC had failed to make a showing of "compelling necessity" sufficient to justify such practice.
Did the lower court err in applying the compelling necessity standard to determine whether the conditions infringed on inmates' rights?
The United States Supreme Court reversed the decision and held that the district court erred in applying the compelling necessity standard to determine whether respondents' rights were infringed upon. The Court held that in determining the constitutionality of conditions of pretrial detention that implicated the protection against deprivation of liberty without due process, the proper inquiry was whether conditions amounted to punishment because under the Due Process Clause, a detainee could not be punished prior to adjudication. Measures taken by respondents served a legitimate, nonpunitive governmental purpose to ensure the security and order of the institution. The Court further held that courts should defer to the expertise of correction officials in the absence of evidence indicating that the officials exaggerated their response to the issues involved in providing detainment.
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