Brown v. Plata
131 S. Ct. 1910
| SCOTUS | 2011Background
- Overcrowding in California prisons far exceeds design capacity (about 156,000 inmates vs ~80,000 design).
- Two related class actions—Coleman v. Brown (mental health) and Plata v. Brown (medical care)—premised on Eighth Amendment violations.
- A three-judge court under the PLRA was convened to fashion relief, including population reductions, to remedy ongoing violations.
- The court ordered California to reduce population to 137.5% of design capacity within two years, allowing transfers and new construction as alternatives.
- The State appealed, arguing the three-judge court process and the remedial population cap exceeded statutory limits and risked public safety.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PLRA §3626(a)(3) conditions for a three-judge court were met | Three-judge court premature/unnecessary | Remedies required by ongoing violations justify convening | Properly convened |
| Whether overcrowding is the primary cause of violations justifying population limits | Overcrowding is the primary cause needing relief | Remedies other than population limits could suffice | Yes; overcrowding identified as primary cause |
| Whether the population cap is narrowly tailored and safeguards public safety | Cap too broad; harms public safety | Cap narrowly drawn; preserves safety | Narrowly tailored; permissible under PLRA |
| Whether a 46,000-prisoner release is justified and enforceable | Release necessary to remedy violations | Release would harm public safety; require alternatives | Upheld under PLRA as remedy necessary to correct ongoing violations |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (deprivation of medical care violates Eighth Amendment unless minimal care)
- Hutto v. Finney, 437 U.S. 678 (U.S. 1978) (limits on judicial remedies for prison conditions)
- Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (courts show deference to prison administration but must enforce rights)
- Turner v. Safley, 482 U.S. 78 (U.S. 1987) (deference to prison officials in administrative decisions but protect constitutional rights)
- Dayton Bd. of Educ. v. Brinkman, 433 U.S. 406 (U.S. 1977) (remedial scope should fit the constitutional violation; limits on broad control)