Prisoners' Rights

Many federal courts have found that mere confinement in some prisons amounted to cruel and unusual punishment. The intervention of federal courts in prison reform began in the early 1970s and continued into the early 2000s. In 1996, eight jurisdictions (Alaska, Mississippi, New Mexico, Rhode Island, South Carolina, Texas, Puerto Rico, and the Virgin Islands) were under court order or a CONSENT DECREE to improve prison conditions. At the same time, major prison facilities in 32 jurisdictions were under court supervision. Typically, federal courts intervene when a facility has serious overcrowding or does not meet minimum standards.

Federal court intervention has forced states to improve prisons through the expenditure of money for new facilities, more staff, and improvements at existing prisons. However, many states have objected to what they perceive as unwarranted federal interference. Congress responded by passing the Prison Litigation Reform Act (PLRA) in 1995, which imposed substantive and procedural limitations on the ability of federal courts to issue injunctions mandating prison reform. The act also restricted the courts' ability to employ special masters to assist in prison condition cases. (A SPECIAL MASTER is a person appointed by the district court to handle the day-to-day details and oversight of a case.) The law has been challenged on many fronts by those seeking reforms in prison conditions.

Lower federal courts have confronted issues posed by the PLRA by finding that the statute restricts their ability to establish minimum prison conditions. In Inmates of Suffolk County Jail v. Rouse, 129 F.3d 649 (1st Cir. 1997), the First Circuit Court of Appeals ruled that the PLRA required a district court to vacate a 1979 consent decree that set conditions for confinement of pretrial detainees in Suffolk County, Massachusetts. In its decision, the court rejected the inmates' contention that the PLRA was unconstitutional because it violated the SEPARATION OF POWERS principle and the Due Process and EQUAL PROTECTION Clauses of the FOURTEENTH AMENDMENT.

The PLRA contains a section that entitles a state or local government entity to the immediate termination of "any prospective relief" previously ordered by a court. Under the act, prospective relief includes all relief other than COMPENSATORY DAMAGES. This definition meant that provisions of the consent decree dealing with the housing of prisoners could be terminated. The First Circuit found that the statute was constitutional and held that the law mandated the termination of the consent decree unless the district court made specific findings that the decree was narrowly drawn to correct a violation of federal law.