Law School Case Brief
Parsons v. Ryan - 754 F.3d 657 (9th Cir. 2014)
Prison officials are constitutionally prohibited from being deliberately indifferent to policies and practices that expose inmates to a substantial risk of serious harm.
A class and a subclass of inmates in Arizona's prison system filed a case against senior officials of the Arizona Department of Corrections (ADC) claiming that they were subject to systemic Eighth Amendment violations. Included as defendants were Charles Ryan as the Director of ADC and Richard Pratt as ADC's former Interim Division Director of Health Services. The inmates alleged that numerous policies and practices of statewide application governing medical care, dental care, mental health care, and conditions of confinement in isolation cells exposed them to a substantial risk of serious harm to which Ryan and Pratt were deliberately indifferent. The inmates sought declaratory and injunctive relief from the alleged constitutional violations. After reviewing the substantial record compiled by the plaintiffs, which included four expert reports, hundreds of internal ADC documents, depositions of ADC staff, and inmate declarations, the district court determined that the inmates met the standard for class certification set forth in Federal Rule of Civil Procedure 23. It therefore certified a class of inmates challenging ADC health care policies and practices, and a subclass of inmates challenging ADC isolation unit policies and practices. The defendants appealed the order.
Was the order certifying a class and a subclass of inmates in Arizona's prison system proper?
The Court held that the certification of the class and subclass was appropriate with respect to Fed. R. Civ. P. 23(a)(2)'s requirement of commonality where the putative class and subclass members set forth numerous common contentions whose truth or falsity could be determined in one stroke: whether the specified statewide policies and practices to which they were all subjected by ADC exposed them to a substantial risk of harm. The Court further held that the district court did not abuse its discretion in determining that plaintiffs had satisfied the typicality requirement of Rule 23(a) where plaintiffs alleged the same or a similar injury as the rest of the putative class, they alleged that this injury was a result of a course of conduct that was not unique to any of them, and they alleged that the injury followed from the course of conduct at the center of the class claims.
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