Brown v. Plata

Following is the case brief for Brown v. Plata, 563 U.S. 493 (2011)

Case Summary of Brown v. Plata:

  • California’s prison population was almost at double its capacity.
  • Because of the overcrowding, a three-judge panel (resulting from two class action suits) determined that the lack of medical and mental health care resulted in an Eighth Amendment violation.
  • Under the Prison Litigation Reform Act (PLRA), the panel ordered that the prison population be reduced to 137.5% capacity given that other measures have not fixed the problem.
  • The State of California appealed, and the U.S. Supreme Court took the appeal from the three-judge panel order.
  • The U.S. Supreme Court held that the panel’s order was correct and that it was justified under authority of the PLRA.  Therefore, it was appropriate for a court to mandate a limit on prison population in response to a constitutional violation.

Brown v. Plata Case Brief

Statement of the Facts:

California’s prison population was almost double what the State had capacity to hold.  The prison conditions prompted two federal class actions.  In both cases, it was determined that the deficiencies in medical and mental health care rose to the level of Eighth Amendment violations, and that reducing prison overcrowding was the only way to remedy the constitutional violations.

Ultimately, the cases were consolidated before a three-judge panel, which had authority through the Prison Litigation Reform Act of 1995.  Hearings were held on the overcrowding problem.

Procedural History:

  • The three-judge panel ordered California to reduce its prison population to 137.5% capacity in two years.  California appealed.
  • The U.S. Supreme Court took the case on appeal.

Issue and Holding:

Does the Prison Litigation Reform Act allow a court to mandate that a State reduce its prison population?  Yes.

Judgment:

The decision of the United States District Courts for the Eastern and Northern Districts of California is affirmed.

Rule of Law or Legal Principle Applied:

A court-mandated prison population limit is necessary to remedy the constitutional violation caused by prison overcrowding, and is authorized by the Prison Litigation Reform Act.

Reasoning:

If a prison is depriving people of adequate medical and mental health care, the courts have a responsibility to remedy the Eighth Amendment violation.  The authority to exercise that responsibility has been placed in the Prison Litigation Reform Act (PLRA).  Appointing a three-judge panel under the PLRA was reasonable, and the panel’s conclusion that the overcrowding was the primary cause of the Eighth Amendment violation was not in error.

The lack of staff coupled with the unsafe and unsanitary conditions of overcrowded prisons more than demonstrated the constitutional violation.  Further, the panel was correct in finding that no other relief, but to limit the prison population, would remedy the violation.  The panel adequately considered the impact on public safety, and it properly noted that public safety would not be adversely affected but releasing low-risk prisoners.  The panel’s ordered remedy was also narrowly tailored and was the least intrusive way to correct the violation.

Concurring and Dissenting Opinions:

Dissenting Opinions (Scalia):

Calling it the majority’s decision a “judicial travesty,” Justice Scalia believes that the court remedy in the case “violates the terms of the governing statute, ignores bedrock limitations on the power of Article III judges, and takes federal courts wildly beyond their institutional capacity.”

Dissenting Opinion (Alito):

Justice Alito states that the “Constitution does not give federal judges the authority to run state penal systems,” and believes that the States are free to make public safety decisions.  Strangely, Justice Alito states that the panel “ordered a radical reduction in the California prison population without finding that the current population level violates the Constitution.”  (That statement, however, seems to be a misunderstanding of the obvious fact that the panel and the Court found the overcrowding created an Eighth Amendment violation).

Significance:

Brown v. Plata is significant because it approved a fairly radical remedy by ordering a prison population reduction in two years, but it was done in the face of an intolerable prison overcrowding problem.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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