Idaho Population Cap Upheld; $155,858.68 in Fees and Cost Awarded; 300+ Prisoners Shipped to Minn. C
Idaho Population Cap Upheld; $155,858.68 in Fees and Cost Awarded; 300+ Prisoners Shipped to Minn. CCA Facility
A federal court in Idaho has refused to lift a 1987 population cap on four housing units at the Idaho State Correctional Institution (ISCI). More than 200 beds were removed and more than 300 prisoners were transferred to a Minnesota private prison as a result of the ruling. Many were later moved to private prisons in Texas.
In 1987, the federal district court issued injunctive relief in a class action lawsuit, capping the population of four ISCI units due to overcrowding. See: Balla v. Idaho State Board of Correction, 656 F.Supp 1108 (D. Id. 1987).
Pursuant to 18 U.S.C. § 3626(b)(1) and (2) of the Prison Litigation Reform Act (PLRA), in 2005 prison officials moved to terminate the 1987 population caps. The ISCI population had grown from approximately 750 in 1987 to 1,416 prisoners in 2005. The court noted that seventeen years after the injunctive orders & Defendants return to court, requesting relief under conditions that are worse & than when the original injunctive orders were put in place.
The court first determined that the 1987 injunctions satisfied the narrow tailoring standard of § 3626(b)(2), and the findings required by the PLRA are implicit in the courts judgment in Balla. It then adopted Balla's extensive findings supporting the population cap.
Over the past several years, Idaho's incarceration rate has generally been in the top ten in the country, often in the top five. Seldom have resources maintained pace with the inmate population increases&. Projected growth in the inmate population over the next four years anticipates an additional 1,300 inmates system wide. No funds have been allocated to mitigate the anticipated growth in the & population, stated the court.
Finding that the record clearly shows current and ongoing constitutional violations, the district court adopted Ballas conclusions of law and injunctive orders. It then determined that the prospective relief ordered in Balla & remains necessary to correct the current and ongoing Eighth Amendment violations at ISCI.
The court then issued a tentative ruling granting the plaintiffs motion for attorney fees and costs, noting that in Dannenberg v. Valadez, 338 F.3d 1070, 1075 (9th Cir. 2003), the Ninth Circuit held that the full amount of attorney fees incurred to obtain injunctive relief may be awarded. The court indicated, however, that it would suspend its ruling if oral argument was requested.
On December 9, 2005, the district court denied the defendants' motion for partial reconsideration, finding that the defendants were reasserting arguments that had been previously presented, considered and rejected. The court also adopted its earlier tentative ruling on attorney fees and costs, awarding plaintiffs attorney fees of $150,054.15 and costs of $5,804.53. See: Balla v. Idaho Bd. of Corrections, 2005 WL 3412806.
In response to the decision, Idaho prison officials transferred more than 300 prisoners to a Corrections Corporation of America (CCA) prison in Appleton, Minnesota, at a cost of $1.1 million not including transportation and recordkeeping expenses.
Shipping prisoners out-of-state was the only option to ease overcrowding, claimed Idaho Department of Corrections Director Tom Beauclair. Apparently sentencing reform, releasing prisoners past their parole dates and similar measures are beyond the pale. Idahos prisons and jails can no longer manage inmate growth and our ability to stretch the system is over, said Beauclair. In addition to the CCA prison, Idaho houses 588 prisoners in county jails, but that is viewed as a short-term remedy because local jails are growing increasingly crowded.
Prison officials plan to ask the state legislature for $160 million to construct three new prisons, and for an additional $7.9 million to cover the cost of housing overflow prisoners both out-of-state and in county jail cells.
Additional Sources: Casper Star Tribune, Spokesman Review, wcco.com
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Related legal case
Balla v. Idaho Bd. of Corrections
|2005 WL 3412806