Supreme Court Decides Brown v. Plata

On May 23, the Supreme Court issued a 5-4 decision in Brown v. Plata, No. 09-1233, affirming the Ninth Circuit's decision that a three-judge court was properly convened under the Prison Litigation Reform Act of 1995 (PLRA) and that the resulting order of that court was supported by the evidence and narrowly tailored to reduce prison overcrowding that had caused constitutional violations.

In 1990, plaintiffs brought suit against the state of California in Coleman v. Brown, alleging that the prison system in the state of California did not provide adequate medical care to mentally ill inmates.  In 2001, in Plata v. Brown, another lawsuit was filed by California state prisoners alleging inadequate prison medical care for inmates with serious medical conditions.  Both of these lawsuits have been the subject of numerous federal proceedings, during which California conceded that deficiencies in medical care constituted violation of prisoners' Eighth Amendment protection against cruel and unusual punishment.  The litigation also resulted in the appointment of a Special Master and a Receiver to monitor and report on the medical care and conditions of the California prison system.  The plaintiffs in both actions moved each district court to convene a three-judge court under the PLRA to order reductions in California's prison system.  After a hearing and lengthy opinion by the three-judge court in the consolidated action, California appealed the order of that panel that required California to reduce its prison population to 137.5% of the prisons' design capacity within two years.  The Ninth Circuit affirmed the order and California appealed.

The Supreme Court affirmed.  The Court began by detailing the facts at issue, including that the California correctional facilities house "nearly double" the number of prisoners they were designed to hold, and the resulting harms such as the effects of overcrowding on the medical care and on the sanitary and safety conditions in the correctional facilities.  As to the merits of the appeal, the Court rejected California's argument that it should have had more time to comply with the previous federal orders before convening a three-judge court.  The "previous order requirement" of the PLRA is satisfied where a court has entered one order that has "failed to remedy" the constitutional violation.  Here, the requirement was satisfied by the previous consent decree and stipulated injunction in 2002, and the 5 years of remedial efforts in Plata and 12 years of efforts in Coleman were sufficient amounts of time to satisfy the previous order requirement.

The Court next addressed the necessary requirements before a population limit control may be ordered under PLRA and determined that the requirements were met in this case.  The Court stated that sufficient evidence demonstrated that "crowding [was] the primary cause of the violation of a Federal right."  It also concluded that the three-judge court did not err by finding that "no other relief will remedy the violation of the Federal right."  Finally, the Court determined that the relief ordered by the three-judge panel was necessary and narrowly tailored to address the constitutional violation.

Justice Kennedy delivered the opinion of the Court, in which Justices Ginsburg, Breyer, Sotomayor, and Kagan joined.  Justice Scalia filed a dissenting opinion that was joined by Justice Thomas.  Justice Alito filed a dissenting opinion that was joined by Chief Justice Roberts.

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