Coleman v. Brown
922 F. Supp. 2d 1004
E.D. Cal.2013Background
- This is a district court Three‑Judge panel decision denying a motion to vacate or modify the 137.5% population reduction order.
- The court previously ordered California to reduce prison population to 137.5% design capacity by December 31, 2013, with interim benchmarks beginning in 2011.
- Defendants sought Rule 60(b)(5) relief to vacate or modify the order, arguing crowded conditions no longer impair constitutional care.
- Supreme Court reaffirmed the 137.5% figure in 2011, endorsing the court’s flexibility and noting possible modification if progress warranted.
- Defendants later terminated the out‑of‑state prisoner program, which would increase population by about 9,500 inmates, casting doubt on durability of any remedy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b)(5) modification/vacatur is warranted | Plaintiffs argue no valid basis to vacate; systemwide relief remains needed | Defendants contend a significant change in facts shows overcrowding no longer blocks constitutionally adequate care | Denied; no basis to vacate under Rule 60(b)(5) |
| Whether there is a significant and unanticipated change in circumstances | Crowding remains a barrier; evidence supports continued need for 137.5% cap | Crowding has been reduced; new evidence shows no barrier | No significant/unanticipated change established; modification denied |
| Whether defendants have achieved a durable remedy | Durable remedy exists if out‑of‑state housing ends and population remains controlled | Durable remedy exists if population can be higher than 137.5% | Durable remedy not shown; out‑of‑state program termination undermines durability |
| Whether ongoing constitutional violations remain warranting systemwide relief | Violations persist in mental health care, requiring continued relief | Violations largely addressed; focus on institution-specific issues | Coleman and Plata ongoing; court continues jurisdiction and complies order |
| Whether the cross‑motion for institution-specific caps is premature | Institution-specific caps may be necessary later | Premature before systemwide cap fully implemented | Denied without prejudice; keep under review once systemwide cap achieved |
Key Cases Cited
- Rufo v. Inmates of Suffolk Cnty. Jail, 502 U.S. 367 (U.S. 1992) (two‑pronged test for Rule 60(b)(5) modifications)
- Horne v. Flores, 557 U.S. 433 (U.S. 2009) (flexible analysis of changed circumstances in institutional reform)
- New York State Ass’n for Retarded Children, Inc. v. Carey, 706 F.2d 956 (2d Cir. 1983) (continuing duty to assess efficacy of injunctions)
- Brown v. Plata, 131 S. Ct. 1910 (S. Ct. 2011) (Supreme Court affirmance of district court’s population‑reduction framework)