Law School Case Brief
Brown v. Plata - 563 U.S. 493, 131 S. Ct. 1910 (2011)
A prison that deprives prisoners of basic sustenance, including adequate medical care, is incompatible with the concept of human dignity and has no place in civilized society. If the government fails to fulfill this obligation, the courts have a responsibility to remedy the resulting Eighth Amendment violation. Courts must be sensitive to the State's interest in punishment, deterrence, and rehabilitation, as well as the need for deference to experienced and expert prison administrators faced with the difficult and dangerous task of housing large numbers of convicted criminals. Courts nevertheless must not shrink from their obligation to enforce the constitutional rights of all persons, including prisoners. Courts may not allow constitutional violations to continue simply because a remedy would involve intrusion into the realm of prison administration.
A three-judge court convened by the U.S. District Courts for the Eastern and Northern Districts of California under 18 U.S.C.S. § 3626 issued an order requiring appellant Governor of the State of California to reduce overcrowding in its prisons to remedy the resulting lack of care available for appellee prisoners with serious medical and psychological conditions. The Governor appealed. The three-judge court credited substantial evidence that prison populations could be reduced in a manner that did not increase crime to a significant degree. Witnesses testified that a 130% population limit would allow the State to remedy the constitutionally inadequate provision of medical and mental health care. The Governor appealed.
Was a federal court allowed under the Prison Litigation Reform Act of 1995 (PLRA) to mandate that a State reduce its prison population?
Establishing the population at which a State could begin to provide constitutionally adequate medical and mental health care, and the appropriate time frame within which to achieve the necessary reduction, requires a degree of judgment under 18 U.S.C.S. § 3626(a). The inquiry involves uncertain predictions regarding the effects of population reductions, as well as difficult determinations regarding the capacity of prison officials to provide adequate care at various population levels. Courts have substantial flexibility when making these judgments. Once invoked, the scope of a district court's equitable powers is broad, for breadth and flexibility are inherent in equitable remedies. Nevertheless, the PLRA of 1995 requires a court to adopt a remedy that is "narrowly tailored" to the constitutional violation and that gives "substantial weight" to public safety. 18 U.S.C.S. § 3626(a). When a court is imposing a population limit, this means the court must set the limit at the highest population consistent with an efficacious remedy. The court must also order the population reduction achieved in the shortest period of time reasonably consistent with public safety.
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