Skip navigation
× You have 2 more free articles available this month. Subscribe today.

Massachusetts’ Corrections Commissioner Has Duty to Comply with Court’s Transfer Order

Massachusetts' Corrections Commissioner Has Duty to Comply with Court's Transfer Order

The First Circuit Court of Appeals has held that a district court has authority to order a Corrections Commissioner to transfer prisoners to create constitutional conditions.

That order came in an action filed by pretrial detainees at Massachusetts' Suffolk County Jail. The district court stated that the "quality of incarceration at Charles Street is 'punishment' of such a nature and degree that it cannot be justified by the State's interest in holding defendants for trial."

That court then ordered the prison officials to reduce the population to accommodate single cell housing. When five months passed without action, the court entered an order requiring all women be transferred to another facility and all convicted men be similarly transferred. This would end multiple celling by creating needed space.

The Commissioner of Corrections appealed that order. The First Circuit noted he did not appeal the original judgment. Instead, in appealing the order in aid of the judgment, he argued he was not engaging in unconstitutional conduct.

The First Circuit found Massachusetts operates a state-wide system of detention and corrections. Thus, the "Jail cannot be viewed in splendid isolation from the rest of the Commonwealth." The Court held that, "The Commissioner's links with county institutions in the integrated system are more than enough to support remedial relief of this nature."

Thus, the district court's order was affirmed. See: Inmates of the Suffolk County Jail v. Eisenstadt, 494 F.2d 1196 (1st Cir. 1974).

As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.

Subscribe today

Already a subscriber? Login

Related legal case

Inmates of the Suffolk County Jail v. Eisenstadt