Law School Case Brief
Rhodes v. Chapman - 452 U.S. 337, 101 S. Ct. 2392 (1981)
Conditions that cannot be said to be cruel and unusual under contemporary standards are not unconstitutional. To the extent that such conditions are restrictive and even harsh, they are part of the penalty that criminal offenders pay for their offenses against society.
Respondents Kelly Chapman and other inmates at an Ohio maximum-security prison brought a class action under 42 U.S.C.S. § 1983 in federal district court against petitioner James A. Rhodes, the governor of Ohio and others, claiming that double prison celling was cruel and unusual punishment in violation of the Eight Amendment. The district court inspected the prison, made findings of fact largely favorable to the prison, and yet ruled the practice was cruel and unusual. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed, holding that the district court's findings were not clearly erroneous and that its conclusions of law were permissible. Rhodes was granted a writ of certiorari.
Did the construction of double ceiling at the prison violate the inmates' Eight Amendment rights?
On certiorari, the Supreme Court of the United States reversed the appellate court's judgment. The Court ruled that double celling at the prison did not constitute cruel and unusual punishment since the district court's conclusion to the contrary was insupportable in that virtually every one of that court's findings of fact tended to refute the inmates' claim. Moreover, the Court ruled, the considerations upon which the district court relied were insufficient to support its constitutional conclusion, fell far short in themselves of proving cruel and unusual punishment, and were properly weighed by the legislature and prison administration, rather than a court. The Court observed that double celling did not lead to deprivations of essentials, nor did it increase violence among inmates or create other conditions intolerable for prison confinement.
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