Part one: complete case summaries in alphabetical order.

Position:Case overview
 
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  1. ADA--Americans with Disabilities Act, State Requirements

  2. ADA--Americans with Disabilities Act, Court Order

  3. Procedures

  4. Class Action, Injunctive Relief

    Armstrong v. Brown, 857 F.Supp.2d 919 (N.D.Cal. 2012). Disabled state prisoners and parolees brought a class action against state prison officials, alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. Seventeen years later, plaintiffs moved for an order requiring officials to track and accommodate the needs of class members housed in county jails and to provide a workable grievance procedure. Following remand to allow the development of additional evidence, the prisoners and parolees filed a renewed motion. The district court granted the motion and entered an enforce order. The court held that: (1) officials' efforts to comply with ADA, the Rehabilitation Act, and prior orders were inadequate and ineffective on a system-wide level; (2) system-wide injunctive relief was appropriate; (3) district court would not abstain from exercising its jurisdiction over matters pertaining to county jails; (4) a stay of the prior order was not warranted; and (5) the district court would exercise its retained jurisdiction to enforce the injunction. The court held that state officials were obliged to ensure ADA-compliant conditions for prisoners and parolees that they housed under their own authority in county jails. (California Youth and Adult Corrections Authority, Board of Prison Terms, California Department of Corrections)

  5. Execution, Privacy

  6. Executions, Media Access, Privacy

  7. Media

    Associated Press v. Otter, 682 F.3d 821 (9th Cir. 2012). A coalition of media corporations filed a [section] 1983 action alleging that a state's denial of the right to witness all stages of executions violated the First Amendment. The district court denied the plaintiffs' motion for a preliminary injunction, and they appealed. The appeals court reversed and remanded, finding that the plaintiffs were likely to prevail on the merits of their claim. The court held that the plaintiffs were likely to prevail, gaining access to all steps in the execution process, beginning with the condemned prisoner's entry into the execution chamber, through insertion of intravenous lines into his body, reading of the death warrant, and pronouncement of death. The state's asserted interests in protecting the dignity of condemned prisoners and the sensibilities of their family and fellow inmates, and in protecting the identity of medical team members who participated in the execution. The court noted that the state already offended the dignity of condemned inmates and the sensibilities of their families and fellow inmates by allowing strangers to watch as they were put to death, that medical team members could wear surgical garb to mask their identities, and there was no evidence that the state was unable to recruit and retain medical team members to participate in executions. (State of Idaho)

  8. Opportunity to Worship, RLUIPA--Religious Land Use and Institutionalized Persons Act

  9. Purpose

    Bader v. Wrenn, 675 F.3d 95 (1St Cir. 2012). A state prisoner filed an action against a Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The district court denied the prisoner's motion for a preliminary injunction and the prisoner appealed. The appeals court affirmed, finding that RLUIPA did not constrain prison transfers based on disadvantages at the transferee prison that were not themselves of the government's creation. According to the court, transfer of the state prisoner for reasons that had not been based on the prisoner's religious practice did not violate RLUIPA although the transfer had the result of restricting his religious opportunities. (Northern Correctional Facility, New Hampshire)

  10. Attorney Fees, Court Costs, PLRA--Prison Litigation Reform Act

  11. Attorney Fees, PLRA--Prison Litigation Reform Act

    Balla v. Idaho, 677 F.3d 910 (9th Cir. 2012). Following completion of litigation against the State of Idaho and the state Department of Corrections, on state inmates' motion for clarification and motion for contempt for failure to comply with an injunction in state inmates' class action challenging conditions of confinement in an Idaho jail, the inmates' attorneys sought fees and costs. The district court awarded costs and fees, and denied the State's motion to stay pending appeal. The state appealed. The appeals court affirmed, finding that the award of attorney fees was warranted. The court found that the award of fees to the law firm appointed to represent the class of state inmates was warranted under the Prison Litigation Reform Act (PLRA), although the inmates' motion for an order to show cause why the State of Idaho and the Department of Corrections should not be held in contempt for violating the injunction was denied because the defendants had brought themselves into conformity with the injunction between the time the motion was filed and the time it was heard, and because the State did not intentionally violate the injunction. The court noted that the object of the motion was to obtain compliance, and counsel's monitoring efforts, including the denied motion, played a key role in resolving the overcrowding issue at the prison. The court awarded a slightly reduced amount: $76,185.60 in attorney's fees, $1,249.20 in costs and $46.94 in postage and office supply costs for the class representative. (Idaho State Correctional Institution)

  12. Medical Care, Wrongful Death

  13. Special Diet

  14. Contract Services, Failure to Protect, Liability

  15. Denial, Inadequate Care, Policies, Private Provider

    Bektic-Marrero v. Goldberg, 850 F.Supp.2d 418 (S.D.N.Y. 2012). The wife of an inmate who died of cancer-related causes while in the custody of a county department of correction (DOC) brought an action against the county, DOC officials, and entities that contracted with the county to provide medical care and treatment to DOC inmates and employees of those entitles. The wife alleged under [section] 1983 that the inmate received inadequate medical care, and asserted related state-law claims for wrongful death and medical malpractice. The defendants moved to dismiss for failure to state a claim and/or for summary judgment. The district court granted summary judgment for the defendants in part, and denied in part. The court held that the physicians who were under contract with the county to provide medical services to inmates at the county jail on a part-time basis acted under the color of state law, within the meaning of 1983, when they treated the inmate, and thus the physicians were subject to liability under, [section] 1983. The court held that the allegations that the health care coordinator for the DOC denied or delayed responding to the wife's request for the inmate's medical records, which she hoped to use to have the inmate's parole restored and to seek a second medical opinion, and that the coordinator expressly denied the wife's request to provide the inmate with a liquid dietary supplement which wife would supply at her own cost, sufficiently pled the coordinator's personal involvement in the alleged deprivation of necessary medical care to the inmate, so as to subject the coordinator to liability under [section] 1983.

    The court found that the United States Department of Justice (DOJ) report which concluded that the provision of medical care to inmates by the county department of correction (DOC) was constitutionally deficient in several respects sufficiently alleged that the county's "custom" of providing inadequate care to inmates was the cause of Eighth Amendment violations sustained by the inmate. (Westchester County Department of Correction, New York)

  16. Mattress, Medical Care

  17. Bedding, Medical Care

  18. Bedding

  19. Qualified Immunity

  20. Deliberate Indifference

    Bell v. Luna, 856 F.Supp.2d 388 (D.Conn. 2012). A state inmate brought a [section] 1983 action against prison officials and a prison doctor, alleging that the defendants subjected him to unconstitutional conditions of confinement and showed deliberate indifference to his serious medical needs, in violation of the Eighth Amendment. The defendants moved to dismiss for failure to state claim. The district court granted the motion in part and denied in part. The court held that the state prison doctor was not deliberately indifferent to the inmate's health in failing to take sufficient measures to treat the inmate's joint and back pain, or in failing to prescribe the inmate with an analgesic cream, as would violate the inmate's Eighth Amendment rights.

    The court found that forcing the inmate to go nearly seven months with a torn, partially unstuffed, unhygienic mattress was a condition of confinement sufficiently serious to implicate the Eighth Amendment. According to the court, the inmate's allegations that a unit manager "willfully, wantonly, and maliciously disregarded" the inmate's repeated requests for an adequate and hygienic mattress stated a claim under [section] 1983 against the manager for cruel and unusual punishment in violation of his Eighth Amendment rights. The court held that the unit manager was not entitled to qualified immunity from the inmate's [section] 1983 claim where the law of the Second Circuit would have put the manager on notice at the time of the alleged violation that failing to provide the inmate with an hygienic, working mattress for over half a year ran afoul of the Eighth Amendment. (MacDougall--Walker Correctional Institution, Connecticut)

  21. Injunctive Relief, Policies/Procedures, RLUIPA- Religious Land Use and Institutionalized Persons Act

  22. Hair Length, RLUIPA--Religious Land Use and Institutionalized Persons Act, Sincerity

  23. Grooming, Hair Length, Religion

    Benning v. Georgia, 845 F.Supp.2d 1372 (M.D.Ga. 2012). An inmate, who was a Torah-Observant Jew, proceeding pro se, brought an action against a state, a board of corrections...

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