Rufo v. Inmates of Suffolk Cty. Jail - 502 U.S. 367, 112 S. Ct. 748 (1992)

Rule:

Although the Court holds that a district court should exercise flexibility in considering requests for modification of an institutional reform consent decree, it does not follow that a modification will be warranted in all circumstances. Fed. R. Civ. P. 60(b)(5) provides that a party may obtain relief from a court order when it is no longer equitable that the judgment should have prospective application, not when it is no longer convenient to live with the terms of a consent decree. Accordingly, a party seeking modification of a consent decree bears the burden of establishing that a significant change in circumstances warrants revision of the decree. If the moving party meets this standard, the court should consider whether the proposed modification is suitably tailored to the changed circumstance.

Facts:

In 1971, inmates at a county jail in Suffolk County, Massachusetts sued the county sheriff, the state commissioner of corrections, the mayor of the city of Boston, and nine city councilors, claiming that inmates not yet convicted of the crimes charged against them were being held at the jail under conditions that violated the Federal Constitution. Based on its holding that conditions at the jail were constitutionally deficient, the United States District Court for the District of Massachusetts permanently enjoined the government officials from housing a pretrial detainee in a cell with another inmate after a certain date, and from housing any pretrial detainees at the jail after a certain later date. In 1978, the United States Court of Appeals for the First Circuit ordered that the jail be closed unless a plan was presented to create a constitutionally adequate facility for pretrial detainees in the county. In response to this order, the District Court was presented with a plan that formed the basis for a consent decree that was entered by the District Court in 1979. The decree, which called for construction of a new county jail that would provide inmates with single-occupancy cells, based the planned capacity of the new jail on a projected decline in inmate population. The case was later litigated in the state courts, and the government officials were ordered by the Supreme Judicial Court of Massachusetts to increase the planned capacity of the jail in response to the fact that the inmate population, rather than declining as projected, had increased. Afterward, the District Court, in 1985, modified the consent decree to permit the capacity of the new jail to be increased in any amount so long as the jail was designed for single-cell occupancy. Subsequently, while the jail was under construction, the county sheriff, based on the increase in the population of pretrial detainees, moved, under Rule 60(b) of the Federal Rules of Civil Procedure--which authorizes a court to relieve a party from a final judgment, order, or proceeding for certain reasons, which reasons are specified (1) in Rule 60(b)(5) as (a) satisfaction, release, or discharge of the judgment, (b) reversal or vacation of a prior judgment on which the judgment is based, or (c) inequitability of continued prospective application of the judgment, and (2) in Rule 60(b)(6), as any other reason justifying such relief--to modify the consent decree to allow double bunking in some of the jail's cells. Holding that Rule 60(b)(5) codified the standard under which nothing less than a clear showing of grievous wrong evoked by new and unforeseen conditions should lead to a change in what was decreed after years of litigation with the consent of all concerned, and that the sheriff has failed to make a case for modification under the "grievous wrong" standard or under Rule 60(b)(6), the District Court refused to grant the requested modification. The Court of Appeals affirmed the judgment of the District Court without elaboration.

Issue:

Did the lower courts apply the correct standard in denying the motion to modify a consent decree entered to correct unconstitutional conditions at the Suffolk County Jail?

Answer:

No.

Conclusion:

The Court held that the Swift "grievous wrong" standard did not apply to requests to modify a consent decree stemming from institutional reform litigation. Instead, the Court adopted a flexible standard whereby the party seeking modification of the consent decree had to establish that a significant change in facts or law warranted revision of the decree and that the proposed modification was suitably tailored to the changed circumstances. The flexible standard was more essential to achieving the goals of prison reform litigation and was more adapted to meeting public interest needs. The party seeking the modification bore the burden of establishing that a significant change in circumstances warranted a revision of the decree. Once the moving party had met its burden, the Court had to determine whether the proposed modification was suitably tailored to the changed circumstances. To that end, the modification could not perpetuate past constitutional violations or rewrite the decree to reach a constitutional floor.