Hutto v. Finney

The Cummins Farm of the Arkansas State Penitentiary was 15,000 acres in size and held approximately 1,000 male inmates. The unit produced cotton, rice, and various other produce. Rather than prison cells, the inmates were housed in open barracks with rows of beds. As most armed guards were inmates serving as "trustees," violent attacks and sexual assaults were common. No rehabilitative or training programs existed.

In 1965, Lawrence J. Holt and several other inmates filed suit against Robert Sarver, Arkansas commissioner of corrections. They claimed their often extended isolation cell confinement, inadequate medical care, and lack of protection from assaults constituted cruel and unusual punishment prohibited by the Eighth Amendment. In an unprecedented response, Federal District Judge J. Smith Henley found that the entire Arkansas system violated the Constitution. The isolation cells were overcrowded and filthy, and the guard trustee system bred hatred and violence. In sum, the overall conditions were "alien to the free world." The court assumed temporary supervision of prison operations.

Until Holt, federal court decisions simply identified the unconstitutional character of specific prison practices. The 1969 decision became a watershed ruling for judicial involvement in prison reform by prescribing detailed remedies. An avalanche of court cases followed across the nation in which prisons and county jails were found unconstitutional.