48 F. Supp. 3d 1318
D. Ariz.2014Background
- This is a class action since 1977 alleging pretrial detainee rights violations in Maricopa County Jail.
- The case originated with a 1981 consent decree addressing pretrial detainee conditions, later superseded by amended judgments.
- A 2008 Second Amended Judgment and a 2012 Third Amended Judgment targeted ongoing constitutional violations in medical, dental, and mental health care.
- Defendants moved in 2013 to terminate the Third Amended Judgment under the Prison Litigation Reform Act (PLRA).
- Plaintiffs opposed termination, prompting an evidentiary hearing in 2014 and a court ruling denying termination and ordering continued remedies and a Fourth Amended Judgment.
- The court held that ongoing constitutional violations persisted as of August 9, 2013, and that remedies beyond the minimum were necessary to protect detainees’ rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PLRA permits termination of the Third Amended Judgment | Plaintiffs contend ongoing violations require continued relief to protect rights | Defendants argue improvements show no current violations and relief is no longer necessary | Termination denied; ongoing relief required |
| Whether there were current and ongoing violations as of Aug. 9, 2013 | Evidence shows persistent deficiencies in intake, care, and mental health | Defendants claim substantial improvements cured systemic problems | Current and ongoing violations persisted; need for continued remedies affirmed |
| What remedies are necessary to cure the violations | Continued oversight and specific measures are needed to protect medical/mental health rights | Remedies should be narrowed and reduced under PLRA standards | Court ordered a Fourth Amended Judgment with concrete actions and deadlines to achieve compliance |
| Are there adequate procedures for providing timely medical and mental health care | Receiving screening, timely face-to-face exams, and meds continuity remain deficient | Improvements in intake, electronic records, and staffing address gaps | Procedures remained inadequate as of Aug. 9, 2013; targeted improvements required |
| Should copayments or resource constraints affect access to care | Cost policies may chill care access for detainees | Policies do not deny care and must be balanced with security/resources | Remedies addressed copayment policies; access not denied for lack of funds under current standards |
Key Cases Cited
- Gilmore v. California, 220 F.3d 990 (9th Cir. 2000) (PLRA standards and termination procedures apply to prison conditions cases)
- Graves v. Arpaio, 623 F.3d 1043 (9th Cir. 2010) (noncompliance history allows greater court involvement in remedies)
- Pierce v. Orange County, 526 F.3d 1190 (9th Cir. 2008) (need-narrowness-intrusiveness standard for termination of relief)
- Bell v. Wolfish, 441 U.S. 520 (Supreme Court 1979) (Due process protections for pretrial detainees; relation to legitimate governmental objectives)
- Hoptowit v. Ray, 682 F.2d 1237 (9th Cir. 1982) (premised on adequate medical/mental health care in prisons)
- Spain v. Procunier, 600 F.2d 189 (9th Cir. 1979) (Eighth Amendment framework evolving with standards of decency)
- Brown v. Plata, 131 S. Ct. 1910 (2011) (Eighth Amendment requirements for medical care; remedial court oversight limits)
- Demery v. Arpaio, 378 F.3d 1020 (9th Cir. 2004) (standards for evaluating pretrial detainee conditions and remedies)
- Trop v. Dulles, 356 U.S. 86 (1958) (Evolving standards of decency; constitutional interpretation adapts over time)
- Wright v. Rushen, 642 F.2d 1129 (9th Cir. 1981) (contextual consideration of confinement conditions)