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El Paso County Jail Conditions Unconstitutional
The Fifth Circuit Court of Appeals reviewed a district court's order that
found conditions at Texas' El Paso County Jail were unconstitutional and
ordered injunctive relief to correct the violations. The district court
ordered that exercise and recreational areas be installed; prisoner diets
be upgraded; medical care be provided; a program for jail personnel,
safety and supervision be instituted; ventilation be maintained; and a
disciplinary program be created. The defendants appealed.
On appeal, the defendants argued they had insufficient funds to implement
the district court's order. The Fifth Circuit held "inadequate resources
can never be an adequate justification for depriving any person of his
constitutional rights." The court was fully satisfied that the totality of
the circumstances of the jail amounted to an Eighth Amendment violation.
The court said that if funds were insufficient to create an outdoor
exercise facility, then an indoor facility should be installed.
The appellate court did not agree that all prisoners should be medically
examined with 36 hours of incarceration; it held medical examinations need
be done only if reasonable grounds existed to protect the prisoner from
himself or others. Next, the appeals court found that while the district
court properly required guards to visit prisoner occupied areas every hour
and a communication system be installed to allow prisoners to alert guards
of emergencies, the court abused its discretion by ordering jail guards to
be paid the same amount as patrol deputies. Additionally, the district
court improperly required the jail to maintain a specific temperature
range without proof that extreme temperatures would be harmful to
prisoners. Finally, the district court properly ordered a system for
disciplinary actions to be instituted. The district court's order was
affirmed in part and reversed in part. See: Smith v. Sullivan, 553 F.2d
373 (5th Cir. 1977).
found conditions at Texas' El Paso County Jail were unconstitutional and
ordered injunctive relief to correct the violations. The district court
ordered that exercise and recreational areas be installed; prisoner diets
be upgraded; medical care be provided; a program for jail personnel,
safety and supervision be instituted; ventilation be maintained; and a
disciplinary program be created. The defendants appealed.
On appeal, the defendants argued they had insufficient funds to implement
the district court's order. The Fifth Circuit held "inadequate resources
can never be an adequate justification for depriving any person of his
constitutional rights." The court was fully satisfied that the totality of
the circumstances of the jail amounted to an Eighth Amendment violation.
The court said that if funds were insufficient to create an outdoor
exercise facility, then an indoor facility should be installed.
The appellate court did not agree that all prisoners should be medically
examined with 36 hours of incarceration; it held medical examinations need
be done only if reasonable grounds existed to protect the prisoner from
himself or others. Next, the appeals court found that while the district
court properly required guards to visit prisoner occupied areas every hour
and a communication system be installed to allow prisoners to alert guards
of emergencies, the court abused its discretion by ordering jail guards to
be paid the same amount as patrol deputies. Additionally, the district
court improperly required the jail to maintain a specific temperature
range without proof that extreme temperatures would be harmful to
prisoners. Finally, the district court properly ordered a system for
disciplinary actions to be instituted. The district court's order was
affirmed in part and reversed in part. See: Smith v. Sullivan, 553 F.2d
373 (5th Cir. 1977).
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