PRISONER RELEASE ORDER | Legal Information Institute

Schwarzenegger v. Plata

Issues

1. Did the three-judge district court have jurisdiction to issue an order releasing inmates from California prisons?

2. If the district court did have jurisdiction, was the prison release order the only option capable of providing adequate physical and mental health services to California inmates while still preserving public safety?

Plata v. Schwarzenegger and Coleman v. Schwarzenegger were separate class actions concerning healthcare conditions in California state prisons. Although the cases were decided separately, they resulted in similar outcomes: the district court in each case determined that the lack of adequate physical or mental care violated the prisoners’ Eighth Amendment rights, leading to years of court orders designed to remedy the violations. After California Governor Arnold Schwarzenegger declared a state of emergency due to prison overcrowding in 2006, the Plata and Coleman plaintiffs argued that the only means of remedying the continued constitutional violations was the release of significant numbers of inmates from state prisons. Subsequently, a three-judge district court convened under the Prison Litigation Reform Act (“PLRA”) issued a prisoner release order. Governor Schwarzenegger and other state officials (“Schwarzenegger”) appealed the decision to the Supreme Court. They contend that the three-judge district court improperly applied the PLRA because California had not had sufficient time to implement the latest court order. Schwarzenegger also contends that the district court failed to determine that overcrowding was the primary cause of the violations. In response, the Plata and Coleman plaintiffs, along with the California Correctional Police Officers’ Association, argue that the PLRA was properly applied because the state was given a reasonable amount of time to comply with previous court orders and the prisoner release order remedied the primary cause of the violations. The Supreme Court’s decision will determine when courts may remedy constitutional violations through a prisoner release order under the PLRA, and could dramatically alter the number of prisoners and the services provided in California prisons.

Questions as Framed for the Court by the Parties

1. Whether the three-judge district court had jurisdiction to issue a “prisoner release order” pursuant to the Prison Litigation Reform Act (“PLRA”), 18 U.S.C. § 3626.

2. Whether the court below properly interpreted and applied Section 3626(a)(3)(E), which requires a three-judge court to find, by clear and convincing evidence, that “crowding is the primary cause of the violation of a Federal right; and . . . no other relief will remedy the violation of the Federal right” in order to issue a “prisoner release order.”

3. Whether the three-judge court’s “prisoner release order,” which was entered to address the allegedly unconstitutional delivery of medical and mental health care to two classes of California inmates, but mandates a system-wide population cap within two years that will require a population reduction of approximately 46,000 inmates, satisfies the PLRA’s nexus and narrow tailoring requirements while giving sufficient weight to potential adverse effects on public safety and the State’s operation of its criminal justice system.

The plaintiffs in Coleman v.