Coleman v. Brown
2013 U.S. Dist. LEXIS 50900
E.D. Cal.2013Background
- In Coleman v. Wilson, the court found Eighth Amendment violations in CDCR’s mental health care and began a long remedial process with a Special Master.
- Defendants moved under 18 U.S.C. § 3626(b) and Rule 60(b)(5) to terminate all relief, terminate judgments, and vacate orders, arguing their system now complies with constitutional requirements.
- The court must assess ongoing violations as of the motion filing date, with the burden on the movant to show no ongoing violations or that relief exceeds what is necessary to cure them.
- Defendants submitted expert reports and the Special Master’s Twenty-Fifth Round Monitoring Report; plaintiffs submitted extensive expert declarations and other evidence challenging deficiencies.
- The court found serious problems with the defendants’ expert evidence due to ex parte inmate interviews and no-contact rule violations, striking those reports from consideration.
- Even after striking tainted evidence, the court concluded that ongoing Eighth Amendment violations persist, so termination of relief is denied and the case remains under continuing remedial orders.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do ongoing constitutional violations remain? | Plaintiffs contend persistent deficiencies in suicide prevention, segregation, access to care, beds, and staffing | Defendants claim the Revised Program Guide and current system cure past violations | Ongoing violations remain; relief not terminated |
| Who bears the burden of proof on § 3626(b) termination? | Gilmore/Graves require plaintiffs to carry burden to show ongoing violations | Defendants bear burden to show no ongoing violations or overbreadth of relief | Burden on defendants; record shows ongoing violations despite defenses |
| Are the defendants' expert reports admissible given ex parte interviews? | Ex parte inmate interviews violated Cal. R. Prof. Conduct 2-100 and tainted reports | Defendants argue interviews were proper and necessary for remediation | Expert reports struck; substantial prejudice found; cannot rely on tainted evidence |
| Is Rule 60(b)(5) relief warranted based on claimed compliance? | Terminating relief would be appropriate if care is constitutionally adequate | Relief premised on compliance; no longer equitable relief if violations persist | Rule 60(b)(5) relief denied; termination denied |
Key Cases Cited
- Coleman v. Wilson, 912 F. Supp. 1282 (E.D. Cal. 1995) (foundation for ongoing remedial obligations in mental health care)
- Gilmore v. California, 220 F.3d 988 (9th Cir. 2000) (burden on defendant in PLRA termination motions)
- Graves v. Arpaio, 623 F.3d 1043 (9th Cir. 2010) (burden-shifting standards and termination framework under PLRA)
- Brown v. Plata, 131 S. Ct. 1910 (U.S. 2011) (systemic prison conditions and population-related remedies; suicide/context relevance)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (Eighth Amendment standard for inadequate medical care)
- Hadix v. Johnson, 367 F.3d 513 (6th Cir. 2004) (future compliance and ongoing relief considerations in prison conditions)
- Sharp v. Weston, 233 F.3d 1166 (9th Cir. 2000) (scope of relief and exhaustion of PLRA termination standards)