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Injunction Against California DOC Precluded By PLRA, Turner
In this unpublished ruling the U.S. Court of Appeals for the Ninth Circuit
held that the California Department of Corrections (CDC) did not have to
comply with plaintiffs' proposed modifications to its procedures for
housing and screening disabled prisoners and that the district court's
injunction requiring it to do so violated the Prison Litigation Reform Act
(PLRA). Learning and physically disabled prisoners brought class action
lawsuit against the CDC for violations of the Rehabilitation Act and the
Americans with Disabilities Act. Most of the issues were resolved in
extensive settlement proceedings. However, plaintiffs disagreed with two
aspects of the CDC's proposed remedy plan--how it planned to house disabled
prisoners (Disability Placement Plan) and the screening process for
identifying them ("verification process")--and forced a district court
resolution.
The district court ordered the CDC to comply with "the plaintiffs'
extensive modifications to these aspects of the plan." On CDC's appeal, the
Ninth Circuit vacated the district court's order and remanded, holding: 1)
The district court applied the wrong legal standard in reaching its
determination. Applying the four-factor test outlined in Turner v. Safely,
482 U.S. 78, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987), the Ninth Circuit, held
that "the CDC's proposed Disability Placement Plan and verification process
[were] 'reasonably' related to legitimate penological interests." 2) Under
the PLRA, "in any civil action with respect to prison conditions [a court]
shall not grant or approve any prospective relief unless the court finds
that such relief is narrowly drawn, extends no further than necessary to
correct the violation of the Federal right, and is the least intrusive
means necessary to correct the violation of the Federal right." The
district court did not make the required findings in this case "with
respect to the negotiated portions of the CDC's proposed remedial plans."
[PLN has reported extensively on this case]. See: Armstrong v. Davis, 215
F.3d 1332 (table), 2000 WL 369622 (9th Cir.(Cal.)).
held that the California Department of Corrections (CDC) did not have to
comply with plaintiffs' proposed modifications to its procedures for
housing and screening disabled prisoners and that the district court's
injunction requiring it to do so violated the Prison Litigation Reform Act
(PLRA). Learning and physically disabled prisoners brought class action
lawsuit against the CDC for violations of the Rehabilitation Act and the
Americans with Disabilities Act. Most of the issues were resolved in
extensive settlement proceedings. However, plaintiffs disagreed with two
aspects of the CDC's proposed remedy plan--how it planned to house disabled
prisoners (Disability Placement Plan) and the screening process for
identifying them ("verification process")--and forced a district court
resolution.
The district court ordered the CDC to comply with "the plaintiffs'
extensive modifications to these aspects of the plan." On CDC's appeal, the
Ninth Circuit vacated the district court's order and remanded, holding: 1)
The district court applied the wrong legal standard in reaching its
determination. Applying the four-factor test outlined in Turner v. Safely,
482 U.S. 78, 107 S.Ct. 2254, 96 L.Ed.2d 64 (1987), the Ninth Circuit, held
that "the CDC's proposed Disability Placement Plan and verification process
[were] 'reasonably' related to legitimate penological interests." 2) Under
the PLRA, "in any civil action with respect to prison conditions [a court]
shall not grant or approve any prospective relief unless the court finds
that such relief is narrowly drawn, extends no further than necessary to
correct the violation of the Federal right, and is the least intrusive
means necessary to correct the violation of the Federal right." The
district court did not make the required findings in this case "with
respect to the negotiated portions of the CDC's proposed remedial plans."
[PLN has reported extensively on this case]. See: Armstrong v. Davis, 215
F.3d 1332 (table), 2000 WL 369622 (9th Cir.(Cal.)).
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Related legal case
Armstrong v. Davis
| Year | 2000 |
|---|---|
| Cite | 215 F.3d 1332 (table), 2000 WL 369622 (9th Cir.(Ca |
| Level | Court of Appeals |
| Attorney Fees | 0 |
| Damages | 0 |
| Injunction Status | N/A |
JOHN ARMSTRONG; JAMES AMAURIC, RICHARD PONCIANO; JACK SWENSEN; BILLY BECK; JUDY FENDT; WALTER FRATUS; GROGORY SANDOVAL; DARLENE MADISON; PETER A. RICHARDSON; STEVEN HILL, Plaintiffs-Appellees, v. GRAY DAVIS, Governor of the State of California; ROBERT PRESLEY, Secretary of Youth and Corrections Agency; C.A. TERHUNE, Director of the Department of Corrections; SUSANN STEINBERG, M.D., Deputy Director for Health Care Services, JUDITH MCGILLIVRAY, Deputy Director of the Planning and Construction Division; DAVID TRISTAN, Deputy Director of the Institutions Division; MIDGE CARROLL, Deputy Director of the Parole Community Services Division, Defendants-Appellants.
No. 99-15152
UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
215 F.3d 1332; 2000 U.S. App.
January 10, 2000, Argued and Submitted, San Francisco, California
April 11, 2000, Filed
NOTICE: [*1] DECISION WITHOUT PUBLISHED OPINION
PRIOR HISTORY: Appeal from the United States District Court for the Northern District of California. D.C. No. CV 94-02307 CW. Claudia Wilken, District Judge, Presiding.
Reported in Full-Text Format at: 2000 U.S. App. .
OPINION:
District court's order VACATED in part and case REMANDED.
No. 99-15152
UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
215 F.3d 1332; 2000 U.S. App.
January 10, 2000, Argued and Submitted, San Francisco, California
April 11, 2000, Filed
NOTICE: [*1] DECISION WITHOUT PUBLISHED OPINION
PRIOR HISTORY: Appeal from the United States District Court for the Northern District of California. D.C. No. CV 94-02307 CW. Claudia Wilken, District Judge, Presiding.
Reported in Full-Text Format at: 2000 U.S. App. .
OPINION:
District court's order VACATED in part and case REMANDED.