Gates v. Collier
Encyclopedia
Gates v. Collier, 501 F.2d 1291
(5th cir. 1972), was a landmark case decided in U.S. federal court
that brought an end to the Trusty system and the flagrant inmate abuse that accompanied it at Mississippi State Penitentiary
at Parchman, Mississippi. It was the first case in a body of law developed in the Fifth Circuit Court of Appeals
holding that a variety of forms of corporal punishment
against prisoners constituted cruel and unusual punishment
and a violation of Eighth Amendment
rights. This case was also the first broad-scale intervention by a court in the supervision of prison practices.
In Gates v. Collier, the Court of Appeals found certain forms of corporal punishment violate the Eighth Amendment, including “handcuffing inmates to the fence
and to cell
s for long periods of time, ... and forcing inmates to stand, sit or lie on crate
s, stump
s, or otherwise maintain awkward positions for prolonged periods.”
Represented by Haber, four Parchman inmates brought suit against the prison superintendent in federal district court alleging violation of their civil rights
under the United States Constitution
by inflicting cruel and unusual punishment
.
In 1972 federal judge
William C. Keady found in favor of the inmates, writing that Parchman Farm violated modern standards of decency. He ordered an immediate end to all unconstitutional conditions and practices. Racial segregation
of inmates was abolished, and the Trusty system
, which allow certain inmates to have power and control over others, was also abolished.
Subsequently other states utilizing the Trusty system
, such as Arkansas
, Alabama
, Louisiana
and Texas
were also forced to abolish it under the Gates v. Collier rulings.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(5th cir. 1972), was a landmark case decided in U.S. federal court
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
that brought an end to the Trusty system and the flagrant inmate abuse that accompanied it at Mississippi State Penitentiary
Mississippi State Penitentiary
Mississippi State Penitentiary , also known as Parchman Farm, is the oldest prison and the only maximum security prison for men in the state of Mississippi, USA....
at Parchman, Mississippi. It was the first case in a body of law developed in the Fifth Circuit Court of Appeals
United States Court of Appeals for the Fifth Circuit
The United States Court of Appeals for the Fifth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Louisiana* Middle District of Louisiana...
holding that a variety of forms of corporal punishment
Corporal punishment
Corporal punishment is a form of physical punishment that involves the deliberate infliction of pain as retribution for an offence, or for the purpose of disciplining or reforming a wrongdoer, or to deter attitudes or behaviour deemed unacceptable...
against prisoners constituted cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
and a violation of Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
rights. This case was also the first broad-scale intervention by a court in the supervision of prison practices.
In Gates v. Collier, the Court of Appeals found certain forms of corporal punishment violate the Eighth Amendment, including “handcuffing inmates to the fence
Fence
A fence is a freestanding structure designed to restrict or prevent movement across a boundary. It is generally distinguished from a wall by the lightness of its construction: a wall is usually restricted to such barriers made from solid brick or concrete, blocking vision as well as passage .Fences...
and to cell
Prison cell
A prison cell or holding cell or lock-up is a small room in a prison, or police station where a prisoner is held.Prison cells are usually about 6 by 8 feet in size with steel or brick walls and one solid or barred door that locks from the outside. Many modern prison cells are pre-cast. Solid doors...
s for long periods of time, ... and forcing inmates to stand, sit or lie on crate
Crate
A crate is a large shipping container, often made of wood, typically used to transport large, heavy or awkward items. A crate has a self-supporting structure, with or without sheathing. For a wooden container to be a crate, all six of its sides must be put in place to result in the rated strength...
s, stump
Tree stump
After a tree has been cut and felled, the stump or tree stump is usually a small remaining portion of the trunk with the roots still in the ground. Stumps may show the age-defining rings of a tree. The study of these rings is known as dendrochronology....
s, or otherwise maintain awkward positions for prolonged periods.”
Case
After years of civil rights protests over the conditions at Parchman, including efforts by the Freedom Riders, civil rights lawyer Roy Haber began to systematically collect evidence of the abuse.Represented by Haber, four Parchman inmates brought suit against the prison superintendent in federal district court alleging violation of their civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
under the United States Constitution
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
by inflicting cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
.
In 1972 federal judge
United States federal judge
In the United States, the title of federal judge usually means a judge appointed by the President of the United States and confirmed by the United States Senate in accordance with Article II of the United States Constitution....
William C. Keady found in favor of the inmates, writing that Parchman Farm violated modern standards of decency. He ordered an immediate end to all unconstitutional conditions and practices. Racial segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
of inmates was abolished, and the Trusty system
Trusty system
The "trusty system" was a strict system of discipline and security in the US made compulsory under Mississippi state law as the method of controlling and working inmates at Mississippi State Penitentiary at Parchman, Mississippi's...
, which allow certain inmates to have power and control over others, was also abolished.
Subsequently other states utilizing the Trusty system
Trusty system
The "trusty system" was a strict system of discipline and security in the US made compulsory under Mississippi state law as the method of controlling and working inmates at Mississippi State Penitentiary at Parchman, Mississippi's...
, such as Arkansas
Arkansas
Arkansas is a state located in the southern region of the United States. Its name is an Algonquian name of the Quapaw Indians. Arkansas shares borders with six states , and its eastern border is largely defined by the Mississippi River...
, Alabama
Alabama
Alabama is a state located in the southeastern region of the United States. It is bordered by Tennessee to the north, Georgia to the east, Florida and the Gulf of Mexico to the south, and Mississippi to the west. Alabama ranks 30th in total land area and ranks second in the size of its inland...
, Louisiana
Louisiana
Louisiana is a state located in the southern region of the United States of America. Its capital is Baton Rouge and largest city is New Orleans. Louisiana is the only state in the U.S. with political subdivisions termed parishes, which are local governments equivalent to counties...
and Texas
Texas
Texas is the second largest U.S. state by both area and population, and the largest state by area in the contiguous United States.The name, based on the Caddo word "Tejas" meaning "friends" or "allies", was applied by the Spanish to the Caddo themselves and to the region of their settlement in...
were also forced to abolish it under the Gates v. Collier rulings.
See also
- Trusty systemTrusty systemThe "trusty system" was a strict system of discipline and security in the US made compulsory under Mississippi state law as the method of controlling and working inmates at Mississippi State Penitentiary at Parchman, Mississippi's...
- Louisiana State PenitentiaryLouisiana State PenitentiaryThe Louisiana State Penitentiary is a prison farm in Louisiana operated by the Louisiana Department of Public Safety & Corrections. It is the largest maximum security prison in the United States with 5,000 offenders and 1,800 staff...
- Cummins UnitCummins UnitThe Cummins Unit is an Arkansas Department of Correction prison in unincorporated Lincoln County, Arkansas, United States. It is located along U.S. Route 65, near Grady, Gould, and Varner, south of Pine Bluff, and southeast of Little Rock.This prison farm is a correctional facility...
- Arkansas and Texas - Pervear v. MassachusettsPervear v. MassachusettsPervear v. Massachusetts, 72 U.S. 475 was a case brought before the United States Supreme Court in 1866 over the issue of prisoners' rights. The court ruled that prisoners have no constitutional rights, not even Eighth Amendment rights. This was the first case stating the "hands off" policy that...
- Holt v. SarverHolt v. SarverHolt v. Sarver is the first in a series of American common law cases that have found entire state prison systems in violation of prisoners' constitutional rights by providing cruel and unusual punishment. In Holt v. Sarver, Arkansas' prison system, which had no written standards, was found in...
- Ruiz v. EstelleRuiz v. EstelleRuiz v. Estelle, 503 F. Supp. 1265 , filed in United States District Court for the Southern District of Texas, eventually became the most far-reaching lawsuit on the conditions of prison incarceration in American history...
- Texas
Further reading
- Oshinsky, David M. "Worse Than Slavery: Parchman Farm and the Ordeal of Jim Crow Justice." The Free Press: NY (1996) ISBN 0684830957.