Coleman v. Brown
28 F. Supp. 3d 1068
E.D. Cal.2014Background
- Motions by plaintiffs seek enforcement and affirmative relief related to use of force, disciplinary measures, and segregated housing in CA prisons.
- Court previously denied termination of this action and held evidentiary hearings on the motions (2013–2014).
- Plaintiffs allege Eighth Amendment violations persist in use of force, disciplinary proceedings, and housing seriously mentally ill inmates in administrative segregation and SHUs.
- As of Sept. 2013 there were over 33,000 outpatient mentally ill inmates in CDCR, with roughly 28% of the inmate population in mental health care.
- The court’s analysis centers on whether defendants have remedied the 1995 Coleman v. Wilson findings and what additional measures are required given the mental health status of the Coleman class.
- Remedies must address (i) policy guidance and training on force against mentally ill inmates, (ii) administrative segregation practices, and (iii) integration of mental health input into housing decisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Have defendants remedied Eighth Amendment violations? | Plaintiffs show ongoing harm and insufficient remediation. | Defendants point to policy revisions and training improvements. | No; violations persist and require further remedial measures. |
| What additional remedial measures are required for use of force? | Need tighter UOF controls and mental-health-sensitive procedures. | Policy revisions and training suffice with enforcement. | Yes; require further policy revisions, training, and monitoring, with sixty-day completion. |
| What remedies are needed for segregated housing of seriously mentally ill inmates? | Non-disciplinary segregation causes harm; need separate units or protections. | Overcrowding and policy adjustments suffice. | Partially granted; require plan within 30 days, phased reductions, and monitoring, plus limits on non-disciplinary segregation stay durations. |
| What is the proper role of mental health clinicians in housing decisions? | Clinicians must have decisive input and limits on overrides by custody. | Custody decisions prevail after consultation. | Defendants must develop a placement protocol ensuring clinician input prevents substantial risk and overrides are limited. |
Key Cases Cited
- Coleman v. Wilson, 912 F.Supp. 1282 (E.D. Cal. 1995) (Eighth Amendment violations in force, segregation, and care of mentally ill inmates; baseline standards established)
- Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (Objective component of Eighth Amendment violations in confinement)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (Test for Eighth Amendment whether deprivation was objectively and subjectively cruel)
- Jordan v. Gardner, 986 F.2d 1521 (9th Cir. 1993) (Standard for ‘wantonness’ / deliberate indifference framework)
- Spain v. Procunier, 600 F.2d 189 (9th Cir. 1979) (Eighth Amendment rights in prison context remain; not forfeited by confinement)
- Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995) (Exclusionary SHU conditions for mentally ill inmates informed by prior rulings)
- Grenning v. Miller-Stout, 739 F.3d 1235 (9th Cir. 2014) (Legitimate penological justification considered in evaluating punishment)
- Keenan v. Hall, 83 F.3d 1083 (9th Cir. 1996) (Penological considerations and standards in confinement)
- Brown v. Plata, 131 S. Ct. 1910 (2011) (Court-approved remedial measures for prison system constitutional violations)