AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and
Detention Facilities
Lockdowns
An African-American
prisoner at a California-state prisoner sued following a lockdown imposed
on African-American inmates, complaining, among other things, of injuries
he suffered related to shower restrictions, and about the race-based classification
of the lockdown. A federal appeals court found that the conditions imposed
did not violate Eighth Amendment restrictions on cruel and unusual punishment,
for which deliberate indifference had to be shown. That did not, however,
bar an equal protection claim for race discrimination under the Fourteenth
Amendment. The trial court erred, on the equal protection claim, in allowing
the jury to defer generally to officials rather than determining whether
the challenged race-based actions were narrowly tailored. Harrington v.
Scribner, #09-16951, 2015 U.S. App. Lexis 7545 (9th Cir.).
A prisoner adequately
alleged a pattern of repeated prison-wide lockdowns for flimsy or no reasons
at all. His grievance only listen two specific lockdowns, but mentioned
14 others and claimed that they were the result of a conspiracy among union
employee and prison officials to artificially create a staff shortage and
negotiate a pay raise. He adequately exhausted administrative remedies.
In a less than three year period, the facility was locked down for 534
days, or more than 50% of the time. While none of the lockdowns were longer
than 90 days, they could violate applicable norms if imposed for some "utterly
trivial" infraction, such as isolated fights, rumors of potential
fights, or no reason. He also stated a viable claim for unlawful deprivation
of exercise when he asserted that it caused him serious medical conditions
and injuries. Eighth Amendment claims for overcrowding, lack of hygiene
and medical care, small cells, and overcrowding had all been the subject
of prior lawsuits against the facility, similar to conditions described
by the plaintiff, and these claims were also viable. Turley v. Rednour,
#11-1491, 2013 U.S. App. Lexis 13571 (7th Cir.).
Conditions in
maximum security prison since "lockdown" began did not constitute
cruel and unusual punishment. Bruscino v. Carlson, 854 F.2d 162 (7th Cir.
1988).
U.S. Supreme
Court rules using lethal force in good faith to quell a prison disturbance
does not violate constitutional rights. Whitley v. Albers, No. 84-1077;
475 U.S. 312 (1986).
Case to continue
over challenge of lockdown conditions. Caldwell v. Miller, 790 F.2d 589
(7th Cir. 1986).
Prisoners claim
emergency response team unnecessarily beat them following riot. Allman
v. Coughlin, 577 F.Supp. 1440 (S.D. N.Y. 1984).
Court upholds
temporary lockdown of inmates while guards attended funeral. Anderson v.
Coughlin, 700 F.2d 37 (2nd Cir. 1983).
Guards, their
union, and prison administrators could be liable for lockdown conditions
and a riot which resulted from illegal labor action. In Re Jackson Lockdown/MCO
Cases, 568 F.Supp. 869 (E.D. Mich. 1983).
Inmates confined
in "lockdowns" may be restrained with chains when they are escorted
to other parts of prison. Fulford v. King, 692 F.2d 11 (5th Cir. 1982).
Ninth Circuit
holds that 48-hour general lockdown did not violate prisoner's constitutional
rights; finds prohibitions on inmate's receiving sexually explicit material
and nude photographs unjustified. Pepperling v. Christ, 678 F.2d 787 (9th
Cir. 1982).
Ninth Circuit
rules that five-month lockdown at California prison was not unconstitutional.
Hayward v. Procunier, 629 F.2d 599 (9th Cir. 1981).