United States v. Territory of the Virgin Islands
884 F. Supp. 2d 399
D.V.I.2012Background
- Defendants moved to terminate prospective relief under PLRA §3626(b)(2); hearing held December 6, 2011.
- Case began in 1986, challenging Eighth Amendment conditions at Golden Grove on St. Croix, Virgin Islands.
- Plaintiff sought to enforce consent-based remedial orders; Defendants argued progress warranted termination.
- The Court’s 2010–2011 proceedings evaluated whether prior orders constitute prospective relief and whether narrow tailoring findings exist.
- The Court concluded that most orders after 1986 are prospective relief, but only the 2006 order contains the required Narrowness-Need-Intrusiveness findings.
- The Court will conduct an evidentiary hearing under §3626(b)(3) to determine current ongoing violations and narrowly tailored relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What orders constitute prospective relief under the PLRA | Plaintiff asserts only the 1986 Decree qualifies | Defendants contend post-1986 orders also constitute prospective relief | All post-1986 orders except the 2006 order are prospective relief |
| Whether the orders have Narrowness-Need-Intrusiveness findings | Findings in 2006 apply to all orders | Findings do not apply to other orders | Only the 2006 Contempt Order contains the required findings; others lack explicit findings |
| Whether there is a current and ongoing violation under §3626(b)(3) | Past findings show ongoing violations | No current and ongoing violation established by record | Evidence requires an evidentiary hearing to determine current ongoing violation and tailoring of relief |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (two-pronged Eighth Amendment standard: objective risk and deliberate indifference)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (state-of-mind standard for prison officials)
- Betts v. New Castle Youth Dev. Ctr., 621 F.3d 249 (3d Cir. 2010) (three-part Farmer-based test for substantial risk of harm)
- Benjamin v. Jacobson, 172 F.3d 144 (3d Cir. 1999) (requires explicit PLRA findings; current and ongoing violation look)
- Cagle v. Hutto, 177 F.3d 253 (4th Cir. 1999) (no post hoc PLRA findings to sustain termination)
- Gilmore v. California, 220 F.3d 987 (9th Cir. 2000) (PLRA findings should be explicit; avoid silent transposition of findings)
- Jones-El v. Berge, 374 F.3d 541 (7th Cir. 2004) (enforcement of consent decree vs prospective relief; distinction under PLRA)