Petitioner
Frank Lee, et al.
Respondent
Caliph Washington, et al.
Petitioner's Claim
That an Alabama law segregating blacks from whites in prisons and jails was constitutionally permissible.
Chief Lawyer for Respondent
Nicholas S. Hare, Special Assistant Attorney General of Alabama
Chief Lawyer for Petitioner
Charles Morgan, Jr.
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Abe Fortas, John Marshall Harlan II, Thurgood Marshall, Potter Stewart, Earl Warren, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
11 March 1968
Decision
The Alabama law segregating blacks from whites in jails and prisons was heldto be unconstitutional under the Fourteenth Amendment.
Significance
The Supreme Court's decision in Lee v. Washington reaffirmed the Court's determination to end segregation, not only in schools but in other publicinstitutions. It also confirmed the right of prisoners to file class action lawsuits against the state.
The Facts of the Case
The state of Alabama had a law on its books that mandated racial segregationin the state penal system and in county, city, and town jails. A group of prisoners being incarcerated in Alabama brought a class action suit challengingthe statute. They sought an injunction to halt the implementation of the segregation system and to have the statute declared unconstitutional. The prisoners' suit was successful. A three-judge panel of the U.S. District Court for the Middle District of Alabama entered a decree declaring the segregation statutes to be in violation of the prisoners' rights under the Fourteenth Amendment to the Constitution. The district court also set up a timetable for desegregation of Alabama's prisons and jails. However, Frank Lee, the Commissionerof Corrections for the state of Alabama, brought a direct appeal to the U.S.Supreme Court, which agreed to hear the case in November of 1967.
The Supreme Court Rules
On 11 March 1967, the Supreme Court issued its decision. A unanimous majorityagreed to affirm the judgement of the district court with regard both to theunconstitutionality of the segregation statute and the advisability of the district court's desegregation schedule. Also, the Court held that prisoners confined in Alabama jails did in fact have standing to bring a class action. As the majority opinion stated: "The State's contentions that Rule 23 of the Federal Rules of Civil Procedure, which relates to class actions, was violatedin this case and that the challenged statutes are not unconstitutional are without merit."
On the large issue at hand, the Court held that statutes requiring segregation in prisons and jails are a violation of the Fourteenth Amendment. Orders directing desegregation regardless of the fact that they failed to make an allowance for the necessities of prison security and discipline were nonethelessconstitutional. "The . . . contention of the State is that the specific orders directing desegregation of prisons and jails make no allowance for the necessities of prison security and discipline," the opinion continued. "But we donot so read the `Order, Judgment and Decree' of the District Court, which when read as a whole we find unexceptionable."
Concurring Opinion
While joining the opinion of the Court, Justices Black, Harlan, and Stewart fashioned a concurrence that emphasized a point they felt was left muted in the majority opinion. They wrote: "[W]e wish to make explicit something that isleft to be gathered only by implication from the Court's opinion. This is that prison authorities have the right, acting in good faith and in particularized circumstances, to take into account racial tensions in maintaining security, discipline, and good order in prisons and jails. We are unwilling to assume that state or local prison authorities might mistakenly regard such an explicit pronouncement as evincing any dilution of this Court's firm commitmentto the Fourteenth Amendment's prohibition of racial discrimination."
Impact
The Supreme Court's decision in Lee v. Washington emboldened other prisoners to file class action suits without fear of having them thrown out of court for lack of standing. It also brought desegregation litigation out of the schools and into the new arena of prisons and jails.
Related Cases
Prisoner Lawsuits
In 1996, Congress passed the Prison Litigation Reform Act (PLRA), which discouraged frivolous lawsuits by inmates. "When asked whether the . . . PLRA hashelped corrections," wrote Susan B. Vandenbraak in Corrections Today,"I inevitably think about one of the inmates serving consecutive life sentences in Pennsylvania . . . To amuse himself, this offender files lawsuits." Vandenbraak went on to say that although this inmate was just one of 35,000 in asingle institution, his litigation constituted three percent of the caseloademerging from the prisons. One case by another inmate involved a complaint because that individual had received crunchy peanut butter rather than smooth.
Clearly such cases are frivolous, and they impose an enormous burden on taxpayers, particularly through costly "consent decrees." But there is another side to the issue, as made plain by a 1997 National Public Radio (NPR) story about inmates who filed a lawsuit against a Georgia prison over what they charged was an unprovoked beating. If true, the incident could constitute a violation of civil rights, and many citizens would agree that prisoners ought to have a right to file such suits. The PLRA, according to Vandenbraak, "carefullyprotect[s] legitimate claims and preserve[s] the full power of the federal court to remedy constitutional violations."
Sources
Levs, Joshua, et al. "Georgia Prison Beatings." All Things Considered,23 July 1997.
Vandenbraak, Susan B. "PLRA: A Step in the Right Direction." Corrections Today, August 1998.
Frank Lee, et al.
Respondent
Caliph Washington, et al.
Petitioner's Claim
That an Alabama law segregating blacks from whites in prisons and jails was constitutionally permissible.
Chief Lawyer for Respondent
Nicholas S. Hare, Special Assistant Attorney General of Alabama
Chief Lawyer for Petitioner
Charles Morgan, Jr.
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Abe Fortas, John Marshall Harlan II, Thurgood Marshall, Potter Stewart, Earl Warren, Byron R. White
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
11 March 1968
Decision
The Alabama law segregating blacks from whites in jails and prisons was heldto be unconstitutional under the Fourteenth Amendment.
Significance
The Supreme Court's decision in Lee v. Washington reaffirmed the Court's determination to end segregation, not only in schools but in other publicinstitutions. It also confirmed the right of prisoners to file class action lawsuits against the state.
The Facts of the Case
The state of Alabama had a law on its books that mandated racial segregationin the state penal system and in county, city, and town jails. A group of prisoners being incarcerated in Alabama brought a class action suit challengingthe statute. They sought an injunction to halt the implementation of the segregation system and to have the statute declared unconstitutional. The prisoners' suit was successful. A three-judge panel of the U.S. District Court for the Middle District of Alabama entered a decree declaring the segregation statutes to be in violation of the prisoners' rights under the Fourteenth Amendment to the Constitution. The district court also set up a timetable for desegregation of Alabama's prisons and jails. However, Frank Lee, the Commissionerof Corrections for the state of Alabama, brought a direct appeal to the U.S.Supreme Court, which agreed to hear the case in November of 1967.
The Supreme Court Rules
On 11 March 1967, the Supreme Court issued its decision. A unanimous majorityagreed to affirm the judgement of the district court with regard both to theunconstitutionality of the segregation statute and the advisability of the district court's desegregation schedule. Also, the Court held that prisoners confined in Alabama jails did in fact have standing to bring a class action. As the majority opinion stated: "The State's contentions that Rule 23 of the Federal Rules of Civil Procedure, which relates to class actions, was violatedin this case and that the challenged statutes are not unconstitutional are without merit."
On the large issue at hand, the Court held that statutes requiring segregation in prisons and jails are a violation of the Fourteenth Amendment. Orders directing desegregation regardless of the fact that they failed to make an allowance for the necessities of prison security and discipline were nonethelessconstitutional. "The . . . contention of the State is that the specific orders directing desegregation of prisons and jails make no allowance for the necessities of prison security and discipline," the opinion continued. "But we donot so read the `Order, Judgment and Decree' of the District Court, which when read as a whole we find unexceptionable."
Concurring Opinion
While joining the opinion of the Court, Justices Black, Harlan, and Stewart fashioned a concurrence that emphasized a point they felt was left muted in the majority opinion. They wrote: "[W]e wish to make explicit something that isleft to be gathered only by implication from the Court's opinion. This is that prison authorities have the right, acting in good faith and in particularized circumstances, to take into account racial tensions in maintaining security, discipline, and good order in prisons and jails. We are unwilling to assume that state or local prison authorities might mistakenly regard such an explicit pronouncement as evincing any dilution of this Court's firm commitmentto the Fourteenth Amendment's prohibition of racial discrimination."
Impact
The Supreme Court's decision in Lee v. Washington emboldened other prisoners to file class action suits without fear of having them thrown out of court for lack of standing. It also brought desegregation litigation out of the schools and into the new arena of prisons and jails.
Related Cases
- Turner v. Safley, 482 U.S. 78 (1971).
- Cruz v. Beto, 405 U.S. 319 (1972).
- Goosby v. Osser, 409 U.S. 512 (1973).
- Jones v. North Carolina Prisoners' Union, 433 U.S. 119 (1977).
Prisoner Lawsuits
In 1996, Congress passed the Prison Litigation Reform Act (PLRA), which discouraged frivolous lawsuits by inmates. "When asked whether the . . . PLRA hashelped corrections," wrote Susan B. Vandenbraak in Corrections Today,"I inevitably think about one of the inmates serving consecutive life sentences in Pennsylvania . . . To amuse himself, this offender files lawsuits." Vandenbraak went on to say that although this inmate was just one of 35,000 in asingle institution, his litigation constituted three percent of the caseloademerging from the prisons. One case by another inmate involved a complaint because that individual had received crunchy peanut butter rather than smooth.
Clearly such cases are frivolous, and they impose an enormous burden on taxpayers, particularly through costly "consent decrees." But there is another side to the issue, as made plain by a 1997 National Public Radio (NPR) story about inmates who filed a lawsuit against a Georgia prison over what they charged was an unprovoked beating. If true, the incident could constitute a violation of civil rights, and many citizens would agree that prisoners ought to have a right to file such suits. The PLRA, according to Vandenbraak, "carefullyprotect[s] legitimate claims and preserve[s] the full power of the federal court to remedy constitutional violations."
Sources
Levs, Joshua, et al. "Georgia Prison Beatings." All Things Considered,23 July 1997.
Vandenbraak, Susan B. "PLRA: A Step in the Right Direction." Corrections Today, August 1998.
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