Split Supreme Court Upholds Ruling to Reduce Cruel and Unusual Punishment in California Prisons

California prisons currently hold twice as many inmates as the prisons were designed to house. As a result of overcrowding, the prisons are incapable of providing basic health care. Prisoners suffering from mental illnesses and those suffering from physical ailments brought separate class action lawsuits to address this problem, which were consolidated in the U.S. Supreme Court in Brown v. Plata. The district courts ruled in both cases that California’s inadequate health care facilities violated the Eight Amendment’s prohibition against cruel and unusual punishment and appointed supervisors to oversee a process to remedy the conditions.

Twelve years after one decision and three years after the other, both court-appointed supervisors determined that no progress had been made in remedying the dangerous and unhealthy conditions. The plaintiffs then moved their respective district courts to convene a three-judge court in accordance with the Prison Litigation Reform Act to reduce the prison population. The three-judge court consolidated the two cases and ruled that California must reduce its prison population to 137.5% of design capacity within two years to bring health conditions up to constitutionally acceptable standards.

Today the Supreme Court upheld the order of the three-judge district court. The Court detailed how the overcrowding has caused mentally and physically ill prisoners to suffer to the point that it violates the Constitution and threatens the safety of prison guards and staff. In his majority opinion, Justice Kennedy wrote that overcrowding “has overtaken the limited resources of prison staff; imposed demands well beyond the capacity of medical and mental health facilities; and created unsanitary and unsafe conditions that make progress in the provision of care difficult or impossible to achieve.”

The Court described how overcrowding denies prisoners minimal mental health care:

Because of a shortage of treatment beds, suicidal inmates may be held for prolonged periods in telephone-booth sized cages without toilets. A psychiatric expert reported observing an inmate who had been held in such a cage for nearly 24 hours, standing in a pool of his own urine, unresponsive and nearly catatonic. Prison officials explained that they had “no place to put him.”

Noting that, in one prison, “up to 50 sick inmates may be held together in a 12- by 20-foot cage for up to five hours awaiting treatment,” and, according to the district court’s extensive fact-finding, one inmate needlessly dies in a California prison every week due to deficiencies in health care, the Court concluded that prisoners with physical illnesses receive “severely deficient” treatment.

The Court also rebutted concerns that the panel’s order would threaten public safety. The opinion quoted the former warden of San Quentin and acting secretary of the California prison system stating that the current system “make[s] people worse, and that we are not meeting public safety by the way we treat people.” The Court also relied on the head of Pennsylvania’s correctional system, an expert witness in the case, who stated that measures to reduce prison population may “actually improve on public safety because they address the problems that brought people to jail.” Other expert witnesses “produced statistical evidence that prison populations had been lowered without adversely affecting public safety” in several different jurisdictions, the Court stated.

The majority concluded that the order to reduce California’s prison population would uphold constitutional protections while protecting public safety. “A prison that deprives prisoners of basic sustenance, including adequate medical care, is incompatible with the concept of human dignity and has no place in civilized society,” Justice Kennedy wrote for the Court. Chief Justice Roberts and Justices Scalia, Thomas and Alito dissented.