Robert Griffin v. James Gomez
741 F.3d 10
9th Cir.2014Background
- Robert Lee Griffin, long-time Aryan Brotherhood leader, was confined in California SHU/ASU units and later convicted in federal RICO proceedings for directing murders and conspiracies tied to the gang.
- In 2006 the district court granted Griffin habeas relief, finding Pelican Bay SHU conditions plus an allegedly illusory release process created an Eighth Amendment violation for him, and ordered his immediate release from the Pelican Bay SHU.
- Griffin was in federal custody when the 2006 order issued; he returned to state custody in 2007, was placed temporarily in Pelican Bay ASU, revalidated as an active gang member in 2008, and transferred to Corcoran SHU.
- Griffin moved to enforce the 2006 order; magistrate and district judges in 2009 and 2011 found the ASU/Corcoran SHU were as restrictive as Pelican Bay SHU and ordered transfer to less restrictive housing or general population.
- California argued changed circumstances (Griffin’s RICO conviction and post-return gang-validation evidence) justified more restrictive housing and sought Rule 60(b) relief; the district court denied the Rule 60(b) motion as premature and later enforcement orders were issued and appealed by the State.
- The Ninth Circuit majority vacated the 2009 and 2011 enforcement orders, holding the district court abused its discretion by (1) failing to account for intervening developments (RICO conviction and 2008 validation) that undercut the 2006 rationale, and (2) overstepping into prison management where deference to administrators is required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prison officials violated the 2006 habeas order by housing Griffin in ASU/Corcoran SHU | Griffin: ASU/Corcoran conditions are as restrictive as Pelican Bay SHU and thus noncompliant with the 2006 order requiring release from SHU | California: 2006 order applied to Pelican Bay SHU at time issued; subsequent revalidation and RICO conviction justify placement in ASU/Corcoran SHU | Court: Vacated 2009/2011 enforcement orders — no violation; intervening developments and deference to prison administrators undermined enforcement |
| Whether changed circumstances (RICO conviction, 2008 validation) could be used to justify returning Griffin to restrictive housing | Griffin: Those developments do not negate the 2006 ruling; housing remained unconstitutionally restrictive | California: Conviction and particularized investigatory evidence show Griffin remained active and dangerous, permitting restrictive housing | Court: These developments undercut the 2006 factual basis; district court abused discretion by ignoring them |
| Whether the district court properly exercised inherent authority to enforce its 2006 order by ordering transfers to less restrictive housing | Griffin: Court enforcement necessary to effectuate habeas relief and avoid evasion by form-over-substance transfers | California: Enforcement orders improperly second-guessed prison management and usurped administrators’ discretion to protect inmates/staff/public | Court: Enforcement orders improperly interfered with prison administration and substituted judicial judgment for prison officials; vacated |
| Proper procedural vehicle for contesting changed circumstances (Rule 60(b) and appeal) | California: Could use Rule 60(b) or appeal to challenge or modify relief in light of new evidence | Griffin: Enforcement actions were appropriate; 2006 order stood absent timely successful Rule 60(b) relief | Court: State raised changed circumstances but had the opportunity to seek Rule 60(b) relief; nevertheless the appellate court considered intervening evidence and vacated enforcement orders on abuse-of-discretion and deference grounds |
Key Cases Cited
- Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995) (describing Pelican Bay SHU’s unique, extreme isolation and its Eighth Amendment analysis)
- Bell v. Wolfish, 441 U.S. 520 (1979) (standard for evaluating prison conditions and deference to administrators)
- Turner v. Safley, 482 U.S. 78 (1987) (deference to prison regulations that are reasonably related to legitimate penological interests)
- Farmer v. Brennan, 511 U.S. 825 (1994) (duty of prison officials to protect inmates from violence)
- Wilkinson v. Austin, 545 U.S. 209 (2005) (SHU confinement implicating liberty interests and conditions of isolation)
- Overton v. Bazzetta, 539 U.S. 126 (2003) (deference to prison administrators’ judgment in restricting privileges for safety)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (scope of district court’s inherent authority to enforce judgments)