Plata v. Schwarzenegger
Encyclopedia
Plata v. Schwarzenegger, docket no. 3:01-cv-01351-TEH (N.D. Cal.
), is a federal class action
civil rights
lawsuit alleging that the California Department of Corrections and Rehabilitation
's (CDCR) medical services are inadequate and violate the Eighth Amendment
, the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1973. As a result of the case, the CDCR's prison medical conditions were found to be in violation of the Eighth Amendment to the United States Constitution
. After repeated violations of a stipulated agreement and order for injunctive relief, the CDCR was held in civil contempt and the medical health care system was placed in receivership
.
The case was consolidated with Coleman v. Schwarzenegger
and assigned to a three-judge court on July 26, 2007 to hear motions for relief pursuant to the Prison Litigation Reform Act
. An order to reduce the prison population was entered on January 12, 2010, which California claims is unconstitutional in its appeal before the Supreme Court
.
for injunctive relief
, which the court approved by court order on June 13, 2002, requiring defendants to provide “only the minimum level of medical care required under the Eighth Amendment.”
. The receivership became effect in April 2006.
and further amended by the Prison Litigation Reform Act
, sets forth remedies with respect to prison conditions. On October 4, 2006 the Governor
Schwarzenegger
issued Proclamation 4278, declaring a state of emergency
. Following the Governor’s issuance of the State of Emergency Proclamation, the plaintiffs in Plata and Coleman filed motions to convene a three-judge court to limit the prison population. During the pending motions, the Little Hoover Commission
released its report titled "Solving California’s Corrections Crisis: Time Is Running Out" and the CDCR Expert Panel on Adult Offender Recidivism Reduction Programming released its report, both advocating a reduction in prison overcrowding. On July 23, 2007 both the Plata and Coleman courts granted the plaintiff's motions and recommended that the cases be assigned to the same three-judge court. The Chief Judge of the United States Court of Appeals for the Ninth Circuit agreed and, on July 26, 2007, convened the instant three-judge district court pursuant to .
The state submitted a plan on September 18, 2009 but the plan failed to meet requirements set by the release order. On October 21, 2009 the court rejected the plan, and gave the government until November 12 to submit a corrected plan or it would order the attorneys for the plaintiff
s to submit a plan and order it implemented. The state submitted a revised plan on November 12, 2009, and the plan was accepted and entered as an order of the court on January 12, 2010.
on January 19, 2010, and the Court postponed jurisdictional questions relating to the appeal on June 14, 2010. It was argued on November 30, 2010.
On May 23, 2011, the Court issued an opinion, Brown v. Plata, No. 09-1233, written by Justice Kennedy. The Court held (1) The three-judge court limits on the prison population were necessary to remedy the violation of prisoners’ constitutional rights and were authorized by the Prison Litigation Reform Act
(PLRA); (2) The three-judge court’s order, subject to the State’s right to seek its modification in appropriate circumstances, must be affirmed.
Justice Scalia wrote a dissenting opinion, to which Justice Thomas
joined.
Justice Alito wrote a dissenting opinion, to which Justice Roberts joined.
and California Attorney General
Jerry Brown
opposed the takeover by a receiver, citing the billions in costs that would have to be incurred to build new medical facilities for prisoners. In March 2009, the court-appointed receiver filed a contempt order against Schwarzenegger and California State Controller John Chiang
for the refusal to turn over $250 million needed to rehabilitate existing medical facilities.
United States District Court for the Northern District of California
The United States District Court for the Northern District of California is the federal United States district court whose jurisdiction comprises following counties of California: Alameda, Contra Costa, Del Norte, Humboldt, Lake, Marin, Mendocino, Monterey, Napa, San Benito, San Francisco, San...
), is a federal class action
Class action
In law, a class action, a class suit, or a representative action is a form of lawsuit in which a large group of people collectively bring a claim to court and/or in which a class of defendants is being sued...
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...
lawsuit alleging that the California Department of Corrections and Rehabilitation
California Department of Corrections and Rehabilitation
The California Department of Corrections and Rehabilitation is responsible for the operation of the California state prison and parole systems. CDC&R is the second largest law enforcement or police agency in the United States behind the New York City Police Department which employs approximately...
's (CDCR) medical services are inadequate and violate 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...
, the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1973. As a result of the case, the CDCR's prison medical conditions were found to be in violation of the Eighth Amendment to the United States Constitution
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...
. After repeated violations of a stipulated agreement and order for injunctive relief, the CDCR was held in civil contempt and the medical health care system was placed in receivership
Receivership
In law, receivership is the situation in which an institution or enterprise is being held by a receiver, a person "placed in the custodial responsibility for the property of others, including tangible and intangible assets and rights." The receivership remedy is an equitable remedy that emerged in...
.
The case was consolidated with Coleman v. Schwarzenegger
Coleman v. Schwarzenegger
Coleman v. Schwarzenegger, docket no. 2:90-cv-00520-LKK-JFM , is a federal class action civil rights lawsuit under the Civil Rights Act of 1871, Eighth and Fourteenth Amendment to the United States Constitution, and the Rehabilitation Act of 1973 alleging unconstitutional mental health care by the...
and assigned to a three-judge court on July 26, 2007 to hear motions for relief pursuant to the Prison Litigation Reform Act
Prison Litigation Reform Act
The Prison Litigation Reform Act is a U.S. federal law that was enacted in 1996. Congress enacted PLRA in response to a significant increase in prisoner litigation in the federal courts; the PLRA was designed to help unclog the court system from this litigation.For the preceding 20 – 30 years,...
. An order to reduce the prison population was entered on January 12, 2010, which California claims is unconstitutional in its appeal before the Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
.
Complaint
The case was filed on April 5, 2001, and re-filed with an amended complaint on August 20, 2001. The alleged deficiencies included inadequate medical screening of incoming prisoners; delays in or failure to provide access to medical care, including specialist care; untimely responses to medical emergencies; the interference of custodial staff with the provision of medical care; the failure to recruit and retain sufficient numbers of competent medical staff; disorganized and incomplete medical records; a “lack of quality control procedures, including lack of physician peer review, quality assurance and death reviews”; a lack of protocols to deal with chronic illnesses, including diabetes, heart disease, hepatitis, and HIV; and the failure of the administrative grievance system to provide timely or adequate responses to complaints concerning medical care. The claims alleged that patients being treated by the CDCR received inadequate medical care that resulted in the deaths of 34 inmate-patients.Stipulation
The plaintiffs and defendants negotiated a stipulationStipulation
In the law of the United States, a stipulation is an agreement made between opposing parties prior to a pending hearing or trial. For example, both parties might stipulate to certain facts, and therefore not have to argue those facts in court. After the stipulation is entered into, it is...
for injunctive relief
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
, which the court approved by court order on June 13, 2002, requiring defendants to provide “only the minimum level of medical care required under the Eighth Amendment.”
Receivership
However, three years after approving the stipulation as an order of the court, the court conducted an evidentiary hearing that revealed the continued existence of appalling conditions arising from defendants’ failure to provide adequate medical care to California inmates. As a result, the court ruled in June 2005 and issued an order on October 3, 2005 putting the CDCR’s medical health care delivery system in receivershipReceivership
In law, receivership is the situation in which an institution or enterprise is being held by a receiver, a person "placed in the custodial responsibility for the property of others, including tangible and intangible assets and rights." The receivership remedy is an equitable remedy that emerged in...
. The receivership became effect in April 2006.
Three-Judge Court
, a statute created by the Violent Crime Control and Law Enforcement ActViolent Crime Control and Law Enforcement Act
The Violent Crime Control and Law Enforcement Act, , , was an act of Congress dealing with crime and law enforcement that became law in 1994. It is the largest crime bill in the history of the US at 356 pages and will provide for 100,000 new police officers, $9.7 billion in funding for prisons and...
and further amended by the Prison Litigation Reform Act
Prison Litigation Reform Act
The Prison Litigation Reform Act is a U.S. federal law that was enacted in 1996. Congress enacted PLRA in response to a significant increase in prisoner litigation in the federal courts; the PLRA was designed to help unclog the court system from this litigation.For the preceding 20 – 30 years,...
, sets forth remedies with respect to prison conditions. On October 4, 2006 the Governor
Governor of California
The Governor of California is the chief executive of the California state government, whose responsibilities include making annual State of the State addresses to the California State Legislature, submitting the budget, and ensuring that state laws are enforced...
Schwarzenegger
Arnold Schwarzenegger
Arnold Alois Schwarzenegger is an Austrian-American former professional bodybuilder, actor, businessman, investor, and politician. Schwarzenegger served as the 38th Governor of California from 2003 until 2011....
issued Proclamation 4278, declaring a state of emergency
State of emergency
A state of emergency is a governmental declaration that may suspend some normal functions of the executive, legislative and judicial powers, alert citizens to change their normal behaviours, or order government agencies to implement emergency preparedness plans. It can also be used as a rationale...
. Following the Governor’s issuance of the State of Emergency Proclamation, the plaintiffs in Plata and Coleman filed motions to convene a three-judge court to limit the prison population. During the pending motions, the Little Hoover Commission
Little Hoover Commission
The California Little Hoover Commission , officially the Milton Marks "Little Hoover" Commission on California State Government Organization and Economy, is an independent California state oversight agency modeled after the Hoover Commission and created in 1962, that investigates state government...
released its report titled "Solving California’s Corrections Crisis: Time Is Running Out" and the CDCR Expert Panel on Adult Offender Recidivism Reduction Programming released its report, both advocating a reduction in prison overcrowding. On July 23, 2007 both the Plata and Coleman courts granted the plaintiff's motions and recommended that the cases be assigned to the same three-judge court. The Chief Judge of the United States Court of Appeals for the Ninth Circuit agreed and, on July 26, 2007, convened the instant three-judge district court pursuant to .
Release Order
On August 4, 2009 the three-judge court ordered that the defendants submit a plan within 45 days detailing "a population reduction plan that will in no more than two years reduce the population of the CDCR’s adult institutions to 137.5% of their combined design capacity." The panel argued that substantial numbers of those in prison could be released without affecting public safety, through such measures as parole reform, community treatment of non-violent prisoners and release of inmates who have demonstrated good behavior.The state submitted a plan on September 18, 2009 but the plan failed to meet requirements set by the release order. On October 21, 2009 the court rejected the plan, and gave the government until November 12 to submit a corrected plan or it would order the attorneys for the plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s to submit a plan and order it implemented. The state submitted a revised plan on November 12, 2009, and the plan was accepted and entered as an order of the court on January 12, 2010.
Supreme Court
California appealed the order to the Supreme CourtSupreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
on January 19, 2010, and the Court postponed jurisdictional questions relating to the appeal on June 14, 2010. It was argued on November 30, 2010.
On May 23, 2011, the Court issued an opinion, Brown v. Plata, No. 09-1233, written by Justice Kennedy. The Court held (1) The three-judge court limits on the prison population were necessary to remedy the violation of prisoners’ constitutional rights and were authorized by the Prison Litigation Reform Act
Prison Litigation Reform Act
The Prison Litigation Reform Act is a U.S. federal law that was enacted in 1996. Congress enacted PLRA in response to a significant increase in prisoner litigation in the federal courts; the PLRA was designed to help unclog the court system from this litigation.For the preceding 20 – 30 years,...
(PLRA); (2) The three-judge court’s order, subject to the State’s right to seek its modification in appropriate circumstances, must be affirmed.
Justice Scalia wrote a dissenting opinion, to which Justice Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
joined.
Justice Alito wrote a dissenting opinion, to which Justice Roberts joined.
Reactions
Governor of California Arnold SchwarzeneggerArnold Schwarzenegger
Arnold Alois Schwarzenegger is an Austrian-American former professional bodybuilder, actor, businessman, investor, and politician. Schwarzenegger served as the 38th Governor of California from 2003 until 2011....
and California Attorney General
California Attorney General
The California Attorney General is the State Attorney General of California. The officer's duty is to ensure that "the laws of the state are uniformly and adequately enforced" The Attorney General carries out the responsibilities of the office through the California Department of Justice.The...
Jerry Brown
Jerry Brown
Edmund Gerald "Jerry" Brown, Jr. is an American politician. Brown served as the 34th Governor of California , and is currently serving as the 39th California Governor...
opposed the takeover by a receiver, citing the billions in costs that would have to be incurred to build new medical facilities for prisoners. In March 2009, the court-appointed receiver filed a contempt order against Schwarzenegger and California State Controller John Chiang
John Chiang (California politician)
John Chiang is a Democratic politician and has been California State Controller since January 8, 2007. He previously served as Chair of the California Board of Equalization and represented the Fourth District, primarily serving southern Los Angeles County...
for the refusal to turn over $250 million needed to rehabilitate existing medical facilities.
External links
- Plata v. Schwarzenegger case profile, Washington University School of LawWashington University School of LawWashington University School of Law , is a private American law school located in St. Louis, Missouri. The law school is one of the seven graduate and undergraduate schools at Washington University in St. Louis....
- Schwarzenegger v. Plata, Scotus wiki