Coleman v. Schwarzenegger
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''Coleman v. Schwarzenegger'', docket no. 2:90-cv-00520-LKK-JFM ( E.D. Cal.), is a federal
class action A class action, also known as a class-action lawsuit, class suit, or representative action, is a type of lawsuit where one of the parties is a group of people who are represented collectively by a member or members of that group. The class actio ...
civil rights Civil and political rights are a class of rights that protect individuals' freedom from infringement by governments, social organizations, and private individuals. They ensure one's entitlement to participate in the civil and political life of ...
lawsuit under the
Civil Rights Act of 1871 The Enforcement Act of 1871 (), also known as the Ku Klux Klan Act, Third Enforcement Act, Third Ku Klux Klan Act, Civil Rights Act of 1871, or Force Act of 1871, is an Act of the United States Congress which empowered the President to suspend t ...
, Eighth and
Fourteenth Amendment to the United States Constitution The Fourteenth Amendment (Amendment XIV) to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Often considered as one of the most consequential amendments, it addresses citizenship rights and ...
, and the
Rehabilitation Act of 1973 The Rehabilitation Act of 1973 () is a United States federal law, codified at et seq. The principal sponsor of the bill was Rep. John Brademas (D-IN-3). The Rehabilitation Act of 1973 replaces preexisting laws (collectively referred to as the V ...
alleging unconstitutional mental health care by the
California Department of Corrections and Rehabilitation The California Department of Corrections and Rehabilitation (CDCR) is the penal law enforcement agency of the government of California responsible for the operation of the California state prison and parole systems. Its headquarters are in Sacrame ...
(CDCR). The case was consolidated with ''
Plata v. Schwarzenegger ''Plata v. Newsom'', Docket No. 4:01-cv-01351-JST (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 ...
'' and assigned to a three-judge court on July 26, 2007 to hear motions for relief pursuant to the
Prison Litigation Reform Act The Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, 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 decrea ...
. 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 A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...
.


History

The case was filed on April 23, 1990, and was tried before a
United States magistrate judge In United States federal courts, magistrate judges are judges appointed to assist U.S. district court judges in the performance of their duties. Magistrate judges generally oversee first appearances of criminal defendants, set bail, and conduct ...
, and in June 1994 the magistrate judge found that defendants’ delivery of mental health care to class members violated the
Eighth Amendment to the United States Constitution The Eighth Amendment (Amendment VIII) to the United States Constitution protects against imposing excessive bail, excessive fines, or cruel and unusual punishments. This amendment was adopted on December 15, 1791, along with the rest of the ...
.


Special Master

On September 13, 1995, the court issued a
permanent injunction An injunction is a legal and equitable remedy in the form of a special court order that compels a party to do or refrain from specific acts. ("The court of appeals ... has exclusive jurisdiction to enjoin, set aside, suspend (in whole or in par ...
and ordered that a
special master In the law of the United States, a special master is generally a subordinate official appointed by a judge to ensure judicial orders are followed, or in the alternative, to hear evidence on behalf of the judge and make recommendations to the jud ...
be appointed to monitor compliance with the court-ordered injunctive relief. The special master submitted 16 interim reports, with later reports "reflect nga troubling reversal in the progress of the remedial efforts of the preceding decade".


Three-Judge Court

In 2006, the plaintiffs in the Coleman case and
Plata v. Schwarzenegger ''Plata v. Newsom'', Docket No. 4:01-cv-01351-JST (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 ...
filed motions to convene a three-judge court to limit the prison population. , a statute created by the
Violent Crime Control and Law Enforcement Act The Violent Crime Control and Law Enforcement Act of 1994, commonly referred to as the 1994 Crime Bill, the Clinton Crime Bill, or the Biden Crime Law, is an Act of Congress dealing with crime and law enforcement; it became law in 1994. It is t ...
and further amended by the
Prison Litigation Reform Act The Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, 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 decrea ...
, sets forth remedies with respect to prison conditions. On October 4, 2006 the
Governor A governor is an administrative leader and head of a polity or political region, ranking under the head of state and in some cases, such as governors-general, as the head of state's official representative. Depending on the type of political ...
Schwarzenegger Arnold Alois Schwarzenegger (born July 30, 1947) is an Austrian and American actor, film producer, businessman, retired professional bodybuilder and politician who served as the 38th governor of California between 2003 and 2011. ''Time'' ...
issue
Proclamation 4278
declaring a
state of emergency A state of emergency is a situation in which a government is empowered to be able to put through policies that it would normally not be permitted to do, for the safety and protection of its citizens. A government can declare such a state du ...
. During the pending motions, the
Little Hoover Commission The California Little Hoover Commission (LHC), 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 a ...
released its report title
"Solving California's Corrections Crisis: Time Is Running Out"
and the CDCR Expert Panel on Adult Offender Recidivism Reduction Programming released it

both advocating a reduction in
prison overcrowding Prison overcrowding is a social phenomenon occurring when the demand for space in prisons in a jurisdiction exceeds the capacity for prisoners. The issues associated with prison overcrowding are not new, and have been brewing for many years. Dur ...
. 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."Order for population reduction plan
three-judge court convened by the Chief Judge of the United States Court of Appeals for the Ninth Circuit hearing ''Plata v. Schwarzenegger'' and ''Coleman v. Schwarzenegger''
The plan would require California to cut 40,000 inmates out of its prison population of 150,000 when the verdict was issued. In an order described by ''
The New York Times ''The New York Times'' (''the Times'', ''NYT'', or the Gray Lady) is a daily newspaper based in New York City with a worldwide readership reported in 2020 to comprise a declining 840,000 paid print subscribers, and a growing 6 million paid ...
'' as "scathing", the panel indicated that the state had failed to follow through on previous orders to improve conditions and that the cuts were needed to deal with overcrowding and poor health care that was causing an unnecessary death each week on average. The panel recommended achieving the cuts by reducing imprisonment of nonviolent offenders and technical parole violators. The state submitted a plan on September 18, 2009 but it 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 A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of the p ...
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.Order to reduce prison population
, three-judge court, convened by the Chief Judge of the United States Court of Appeals for the Ninth Circuit hearing ''Plata v. Schwarzenegger'' and ''Coleman v. Schwarzenegger''


Supreme Court

California appealed the order to the
Supreme Court A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...
on January 19, 2010, and
certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
was granted on June 14, 2010. It was argued on November 30, 2010.
Oyez Oyez (, , ; more rarely with the word stress at the beginning) is a traditional interjection said two or three times in succession to introduce the opening of a court of law. The interjection is also traditionally used by town criers to attract t ...
In a bare majority opinion by Justice
Anthony Kennedy Anthony McLeod Kennedy (born July 23, 1936) is an American lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1988 until his retirement in 2018. He was nominated to the court in 1987 by Presid ...
issued in 2011, the Court affirmed the order. in Brown v. Plata, 131 S. Ct. 1910 (2011).


See also

*
Plata v. Schwarzenegger ''Plata v. Newsom'', Docket No. 4:01-cv-01351-JST (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 ...


References

{{Reflist


External links


Coleman v. Brown
case profile,
Civil Rights Litigation Clearinghouse The Civil Rights Litigation Clearinghouse is a website that serves as a searchable resource for information and documents relating to civil rights litigation. The Clearinghouse was founded by law professor Margo Schlanger in 2005, at Washington U ...

Schwarzenegger v. Plata
Scotus wiki Penal system in California 2009 in United States case law United States Court of Appeals for the Ninth Circuit cases 2009 in California Law articles needing an infobox Mental health law in the United States