Holt v. Sarver
Encyclopedia
Holt v. Sarver is the first in a series of American common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...

 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
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...

' prison system, which had no written standards, was found in violation of United States constitutional law. These cases have significantly altered the American prison
Prison
A prison is a place in which people are physically confined and, usually, deprived of a range of personal freedoms. Imprisonment or incarceration is a legal penalty that may be imposed by the state for the commission of a crime...

 system, specifically with regard to prisoners' rights under the 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...

.

Arkansas cases

In 1969 in Holt v. Sarver I, 300 F. Supp. 825, Judge J. Smith Henley ruled several aspects of Arkansas' existing prison system unconstitutional
Constitutionality
Constitutionality is the condition of acting in accordance with an applicable constitution. Acts that are not in accordance with the rules laid down in the constitution are deemed to be ultra vires.-See also:*ultra vires*Company law*Constitutional law...

. He issued guidelines to follow for correcting the problems, and ordered administrators to report on the progress of the implementation of these guidelines.

In 1970 in Holt v. Sarver II, 309 F. Supp. 362, Judge Henley ruled the entire Arkansas prison system unconstitutional and ordered the State Correction Board to devise a plan of action. In that same case in 1971, Judge Henley enjoined the Arkansas prison from preventing the inmates' access to court and from 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...

 upon them.

Prior history

The Supreme Court ruled in Jones v. Cunningham
Jones v. Cunningham
Jones v. Cunningham, 371 U.S. 236 was a Supreme Court case in which the court first ruled that state inmates had the right to file a writ of habeas corpus challenging both the legality and the conditions of their imprisonment. Prior to this, starting with Pervear v...

in 1963 that inmates in state institutions could file a writ of habeas corpus challenging the conditions of their imprisonment as well as its legality. This ruling reversed the Supreme Court's "hands off" policy regarding federal interference in state penal issues first clearly stated in 1866 in Pervear v. Massachusetts
Pervear v. Massachusetts
Pervear 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...

. Subsequently, in a series of cases starting with Gates v. Collier
Gates v. Collier
Gates v. Collier, 501 F.2d 1291 , 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...

the federal government began whole scale intervention in the constitutionality of the operation of state prison systems.

External links

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