Hutto v. Finney

Hutto v. Finney was a sequel to Holt v. Sarver and within this context, inmates objected again to the prison living conditions and disciplinary methods used by the Arkansas prison system. The state correctional system would confine as many as 11 people to isolation cells "eight-by-ten foot rooms without windows" for indefinite periods of time. These isolation cells provided only a sink and a toilet that could only be flushed from outside. Furthermore, inmates confined to the isolation cells received mattresses at night, which were collected in the morning, and although some prisoners had infectious diseases, the mattresses were randomly distributed the next night--a practice that could easily spread diseases around the prison. Prisoners considered these conditions a violation of their constitutional rights, a view the district court already shared.

Hearing the trial first, the U.S. District Court for the Eastern District of Arkansas determined that the prison conditions did constitute cruel and unusual punishment. In addition, the court ordered that the Arkansas Department of Correction limit the number of inmates confined in each isolation cell, place a bunk in each cell, stop the low-calorie diet in isolation cells, and confine prisoners to isolation cells for no more than 30 days. Furthermore, the court argued that prison officials acted in bad faith by not improving prison conditions as ordered by previous court decisions and consequently awarded the respondents' attorney's fees paid by the Department of Correction. The Department of Correction appealed the award of attorney's fees as well as the 30 day maximum limit. The U.S. Court of Appeals for the Eighth District agreed with the district court's decision and charged the Department another attorney's fee for the appeal services.

Hutto and the Arkansas Department of Correction then took their dispute to the Supreme Court, maintaining that a isolated confinement period of more than 30 days did not violate prisoner's constitutional rights and that the Department of Correction, as a branch of the state government, was immune to the lower courts' award of attorney's fees under the Eleventh Amendment.

In June of 1978, the U.S. Supreme Court finished reviewing the Federal District Court's decision and upheld its 30-day limit on confinement in isolation cells because the lower court had given the Arkansas correctional system repeated opportunities to improve the cruel and unusual conditions in the isolation cells. The Court reasoned that the 30-day limit would prevent overcrowding and hostility resulting from long periods of confinement, and that this limit would not interfere with prison operations and administration. Moreover, the Supreme Court majority agreed with the district court's awarding of fee to be paid out of the state's Department of Correction's budget, supporting its finding that prison officials acted negligently in not correcting the system's violations of the Eighth and Fourteenth Amendments. The majority concluded that the Civil Rights Attorney Fees Awards Act of 1976 supported the Court of Appeals decision, since the other party prevailed.