AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law
for Jails, Prisons and Detention Facilities


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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).

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