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Americans live in a time of the greatest prison expansion in the modern history. By the close of 2000, almost two million adults were imprisoned at an operational cost that exceeds over $38 billion dollars a year. Minorities are represented in the prison population in percentages that far exceed their representation in the general population. African Americans comprise less than 13 percent of the U.S. population, yet 48 percent of the prison population is African American. With so many people in prison and with so much spent to keep them there, the rights of prisoners takes added significance. An additional factor is that every year more than a half million men and women prisoners are released. The treatment these people received in prison—whether it conforms to constitutional norms or not—will have consequences. It could very well mean the difference between having prisoners return to their communities embittered or having them return ready to begin law-abiding lives.
This research paper will trace the history of prisoners’ rights, and will provide a general description of the current state of the law. This review provides a context for considering the likely direction of future developments.
History of Prisoners’ Rights
The history of the development of the rights of prisoners occurred over three distinct historic periods. The first, and longest lasting, was the period in which the ‘‘hands-off doctrine’’ prevailed. The second was the period of the civil rights era, which saw the evisceration of the hands-off doctrine and the birth of the idea that prisoners could have enforceable rights. The third, and current, period is one of retrenchment. During this period the U.S. Supreme Court, through a series of decisions, has both elaborated upon and diminished the rights of prisoners. In addition, Congress has intervened through the enactment of the Prison Reform Litigation Act (PLRA), a law that severely limits the ability of prisoners to seek vindication of their rights in court.
The Hands-off Period
During most of the history of the United States, prisoners had no legal right to humane conditions of confinement that could be judicially enforced. This view was so strong that one much-cited case even described a suing prisoner as a ‘‘slave of the state’’ (Ruffin v. Commonwealth, 62 Va. (21 Gratt) 790, 796 (1871)).
The hands-off doctrine precluded judges from determining what rights survived incarceration. Judges refused to intervene on the ground that their function was only to free those inmates illegally confined, not to superintend the treatment and discipline of prisoners in penitentiaries. The pull of the hands-off doctrine was so strong that claims of racial discrimination were not heard. Even safety issues were ignored. In one case, a federal court refused to hear from inmates whose lives were endangered by being held in overcrowded conditions in a firetrap. Even under these conditions, because of the hands-off doctrine, the judge declined to intervene (Ex parte Pickens, 101 F.Supp 285, 287, 290 (D.Alaska 1951)).
Underlying the hands-off doctrine were concerns about the appropriate reach of federal judicial power. Courts feared that separation of powers and federalism would be violated if courts intervened in the operation of state penal institutions. They would be using federal power to dictate to the states how to run their own institutions—the management and control of these institutions are generally viewed as executive and legislative functions. By adjudicating claims in favor of the state inmates, the federal courts also expressed concern that, contrary to principles of federalism, they would be intervening in state affairs. Finally, the courts doubted their ability to fashion meaningful relief when improvements in prison conditions required additional funding.
The attitude of the courts and the prison officials worked hand-in-hand to deny prisoners’ rights. The courts believed that they lacked the expertise to become involved in prison management and the corrections officials perceived judicial review as a threat to internal discipline and authority. The specter of excessive workloads may have influenced judges also. With large numbers of prisoners willing to press a wide variety of claims, judges invoking the hands-off doctrine may have done so to avoid being inundated with prisoner petitions. Even if the petitions proved meritorious, a judge would have to spend a great deal of time handling the case. The hands-off doctrine served to ease the court’s workload; once the court determined the claim was based on a prisoners’ rights theory, the suit was automatically dismissed. But, the doctrine imposed costs, the most serious being that the merits of potentially worthy complaints were never reached. This meant that there was little judicial pressure to improve prison conditions.
The hands-off doctrine was eventually discredited. Courts and commentators began to recognize that the separation of powers does not foreclose judicial scrutiny when the legislature or executive acts unconstitutionally (Note). They also recognized that courts regularly invalidate laws that violate citizens’ constitutional rights. In fact, a major function of courts in the U.S. constitutional system is to ensure that constitutional rights are preserved and protected.
The argument that courts lack expertise in prison management was also criticized. The argument is based on a misconception of the judiciary’s role. The consideration of a particular practice on constitutional grounds rarely, if ever, requires a court to assume management of the penal institution. Even when it orders changes in policy a court does not have to engage in management of an institution. That can be left to prison officials who have the authority to find the best way administratively to implement the court’s decision.
Further, arguments of counsel and the taking of testimony, including the testimony of expert witnesses, supply the expertise needed for accurate decision-making by the court. The courts have an additional supervisory resource— the use of appointed masters to assist in carrying out their orders. Finally, the possibility of ‘‘opening the floodgates’’ to frivolous petitions has always been the cost of operating a judicial system. This possibility has never been deemed a valid excuse for denial of constitutional rights. The courts have procedural means to control the filing of frivolous suits without refusing to entertain the meritorious actions. (Moreover, new restrictive methods of controlling this problem have been legislated through the Prison Reform Litigation Act, which is discussed below.)
The Beginnings of Prisoners’ Rights Law— The Civil Rights Era
In the 1960s and early 1970s, the growth of the civil rights movement rendered the ‘‘handsoff’’ doctrine increasingly vulnerable to attack. It was difficult to maintain the validity of the handsoff doctrine at a time of rising expectations for fair and equal treatment by government.
Several forces combined during the 1960s to increase the number of prison cases and shake the noninterventionist foundations of the doctrine. First, prisoners were becoming increasingly militant and assertive. The Black Muslims’ successful First Amendment challenge to prison officials who ignored or punished their efforts to practice their religion represented some of the first courtroom victories for prisoners (Pierce v. LaVallee, 293 F.2d 223 (2d Cir. 1961); Sewell v. Pegelow, 291 F.2d 196 (4th Cir. 1961)). These victories opened the door to litigation on a variety of prison-related issues.
Second, the emergence and growth of a civil rights–civil liberties bar in the legal profession coupled with private foundation and public funding under the legal services program provided the expertise and funding for effective prisoner litigation. Overburdened courts that easily dismissed the complaints of pro se prisoners with limited education and little, if any, legal training could not so readily dismiss the same complaints properly filed by attorneys. Legal support of the cause was buttressed by public and media support as prison reform and the more humane treatment of prisoners became popular reformist themes after the release of a presidential crime commission report in 1967 (President’s Commission). Finally, a new federal crimecontrol program, the Omnibus Crime Control and Safe Streets Act of 1968, was enacted, providing visibility and financial incentives for correctional reform.
Third, the judiciary was becoming more responsive to the plight of society’s underprivileged. Nationally, the Supreme Court expanded the rights of the individual in relation to the state. These opinions began to establish the principles that federal courts have a special role in protecting the rights of ‘‘discrete and insular minorities’’ who are politically powerless. Prisoners are, by and large poor, minority persons whose needs command little respect in state legislatures—exactly the type of individuals that needed the protection of the courts. Supreme Court decisions helped prisoners assert their rights in two other ways: the Court’s extension of most of the provisions of the Bill of Rights to the states allowed prisoners housed in state institutions to sue for violations of federal constitutional rights; and, the Court’s resurrection of the Civil Rights Statute (42 U.S.C. § 1983) provided prisoners with an attractive procedural avenue for challenging prison conditions and practices in federal courts.
Finally, the public, including judges, became increasingly aware of the sordid conditions that often characterized prison life. Remote locations and highly restrictive visitation and mail policies complicated discovery of the activities behind prison walls. But prisoner strikes and riots, like the uprising in Attica, New York, in 1971 brought the reality of prisons to the attention of the public. Widely read books by prison authors like Eldridge Cleaver, Malcolm X, and George Jackson also helped raise the consciousness of the public. Likewise, these independent sources of knowledge about prison conditions may have raised the credibility of prisoner complaints in the eyes of judges. All these ingredients set the stage for the courts to begin the development of prisoners’ rights law, as the hands-off doctrine declined.
Because of these factors, lower court judges began, almost for the first time, to consider the claims of inmates. Litigation, about conditions of confinement, whether in the horrendous prison systems of Arkansas, Alabama, and Mississippi or the infamous ‘‘Tombs’’ jail in lower Manhattan, New York, forced the lower courts of the 1970s to come face-to-face with the grimmest conditions of human confinement (See, e.g., Rhem v. Malcom, 371 F.Supp 594, 672 (S.D.N.Y.), affd, 507 F.2d 333 (2d Cir. 1974), affd on remand, 527 F.2d 1041 (2d Cir. 1975); Holt v. Sarver, 309 F.Supp 362 (E.D.Ark 1970), affd, 442 F.2d 304 (8th Cir. 1971); Newman v. Alabama, 559 F.2d 283 (5th Cir. 1997), cert denied, 438 U.S. 915 (1978)).
These cases established that judicial review of the complaints of prisoners for more humane treatment was the new reality—very much a ‘‘handson’’ approach. Indeed, prison conditions were so poor during this period and the courts so willing to consider prisoner complaints that by the middle of the 1980s prisons in some forty-five states plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands were operating under some form of court order to correct constitutional violations (‘‘Status Report’’).
The hands-off doctrine formally ended with two decisions from the Supreme Court in the early 1970s. In the first decision, Justice Byron White explicitly sounded the death knell for the hands-off doctrine in a single line: ‘‘[T]here is no Iron Curtain between the Constitution and the prisons of this country’’ (Wolf v. McDonnell, 418, U.S. 539, 555-56 (1974)). At about the same time, Justice Lewis A. Powell, writing for the Court, stressed that when a prison regulation or practice offends a fundamental Constitutional guarantee the federal courts will exercise their duty to protect those rights (Procunier v. Martinez, 416 U.S. 396, 405-06 (1974)). Since then, the Supreme Court has continually asserted that the hands-off doctrine has no place in constitutional jurisprudence (See, e.g., Thornburgh v. Abbott, 490 U.S. 401, 407 (1989) (‘‘[p]rison walls do not form a barrier separating prison inmates from the protections of the Constitution’’); Turner v. Safley, 482 U.S. 78, 84 (1987)(same); Rhodes v. Chapman, 452 U.S. 337, 352 (1981) (‘‘courts have a responsibility to scrutinize [prisoners’] claims. . .’’); Bell v. Wolfish, 441 U.S. 520, 562 (1979)). It is now settled law that ‘‘hands-off’’ ends where the abridgement of constitutional rights begins.
But to say that inmates have rights is not to list the specific constitutional rights they retain nor is it to chart their boundaries. The elaboration of prisoners’ rights that began during the civil rights era continues today, but the current period is also marked by retrenchment.
Elaboration and Retrenchment
Beginning in the late 1970s and early 1980s the elaboration of prisoners’ rights by the courts was characterized by a move toward retrenchment. This retrenchment was signaled by two significant developments. First, the Supreme Court under Chief Justice Warren E. Burger (1969 to 1986), and especially under William H. Rhenquist (appointed Chief Justice in 1986), grew increasingly unreceptive to the claims of ‘‘discrete and insular minorities.’’ Second, the Congress, responding to critics who claimed that the lower courts had moved too far in protecting the rights of inmates, passed the Prison Reform Litigation Act, which restricted inmate access to the courts. While these developments did not return the law to the old and discredited ‘‘hands off’’ era, they did leave the law governing prisoners’ rights far more restrictive than the law that governs the constitutional rights of free world citizens.
The Supreme Court
The key question for the Court once the hands-off doctrine fell became what standard to apply in determining prisoners’ rights. A high standard will mean that more rights will be recognized in practice. A lax standard, placing a burden on prisoners that is difficult to meet, might mean that the rights are more theoretical than real. In a series of cases, the Supreme Court has marked out at least three distinct approaches to this question depending upon the nature of the specific right being asserted. While the tests differ, the similarities are greater than the differences. Regardless of the test, caution and considerable deference to prison administration is the hallmark of the Supreme Court’s restrictive approach.
A prime illustration of this retrenchment is Turner v. Safley, 482 U.S. 78 (1987), a case that dealt with First Amendment rights of inmates to communicate with one another and to marry. Normally First Amendment rights are given the highest protection from infringement and cannot be abridged unless government has a compelling interest in the restriction. However, in Turner a closely divided court, by a vote of five to four, held that an application of this standard would seriously hamper the ability of prison officials to anticipate security problems and to adopt solutions to what it saw as the ‘‘intractable’’ problems of prison administration. Additionally, the court warned that applying this very high standard would mean that the courts would become the primary arbiters of what constitutes the best solution to every administrative problem. Accordingly, the Court chose a variation of a ‘‘reasonable relationship’’ test, the lowest level of constitutional justification, normally reserved for the analysis of governmental regulations that merely intrude on economic not political rights.
Using this standard the Court held that a prison rule that restricts First Amendment rights of inmates to communicate with one another is valid if it is reasonably related to a legitimate penological interest. To make that determination the Court considered four factors: (1) whether there is a logical connection between the restriction at issue and the governmental interests invoked to justify it; (2) the availability of alternative means to exercise the restricted right; (3) the impact that accommodation of the right might have on other inmates, on prison personnel, and on allocation of prison resources generally; and (4) whether there are ‘‘obvious, easy alternatives’’ to the challenged policy that could be adopted at a minimal cost.
With this highly deferential and open-ended approach it is very difficult, but not impossible, for an inmate to show that restrictions are unconstitutional. The Turner approach has become the Court’s most frequently used approach to determine whether restrictions imposed on inmates are unconstitutional. It has been used, for example, in cases involving religious liberties (O’Lone v. Shabazz, 482 U.S. 342 (1987)), and in cases involving communication and expression— ‘‘speech’’ between prisoners and the outside world (Thornburgh v. Abbott, 490 U.S. 410, 109 S.Ct. 1874 (1989)).
An even clearer illustration of the Supreme Court’s policy of retrenchment is found in the Court’s treatment of cases in which inmates claim that the conditions of confinement violate the Eighth Amendment’s prohibition on ‘‘cruel and unusual punishment.’’ In one of the earlier prison conditions cases the Supreme Court had intimated that the Eighth Amendment is violated whenever the conditions of confinement fall below ‘‘the minimal civilized measure of life’s necessities’’ (Rhodes v. Chapman, 452 U.S. 337 (1981)). In the 1990s, however, the Court dramatically changed this standard by superimposing a new, and additional, test for determining whether conditions of confinement violate the Eighth Amendment. Under the new test, conditions that are objectively uncivilized will not be held unconstitutional unless there also is a finding that the prison officials’ subjective intent was to subject an inmate to cruel and unusual punishment (Wilson v. Seiter, 111 S.Ct 2321 (1991)). Thus, a prison that is severely overcrowded may no longer violate the Constitution, even if conditions are shocking, unless the court finds that the prison officials intended to create these conditions.
A third example of retrenchment is the Court’s procedural due process model for resolving issues relating to prison disciplinary decisions. Under this model, a prisoner is not entitled to a due process hearing—even if a sanction is imposed on the prisoner as punishment—unless the sanction imposes an ‘‘atypical and significant hardship’’ beyond that which is generally inherent in the ‘‘ordinary incidents of prison life.’’ The Court adopted this vague and difficult test in part because it believed that prisons are different from larger society, more dangerous and more in need of the application of administrative discretion (Sandin v. Conner, 115 S.Ct 2293 (1995)).
What all three of the examples above have in common is that they utilize a very different scale for measuring whether an inmate’s rights have been violated than the scale the Court uses for determining the constitutional rights of persons who are not in prison. The Court’s deferential standards have been criticized on a number of grounds. They provide prison officials with broad discretion to curtail and abolish many basic rights of the incarcerated with minimal justification. The tendency of the Court to subject fundamental constitutional rights of prisoners to low standards suggests the Court does not recognize any hierarchy of values among constitutionally protected interests. This trivializes important constitutional rights by treating the First Amendment rights to go to church or read a book in the same manner as the right of an inmate to possess small items of personal property in his cell. Moreover, there is a substantial amount of ambiguity in the nature of judicial scrutiny called for by the Court’s deferential tests. Perhaps most telling is the complaint that the Court has been inching the law back to the now thoroughly discredited hands-off doctrine.
The Prison Litigation Reform Act of 1995
Congress added to the barriers created by the Supreme Court when it passed the Prison Litigation Reform Act (PLRA), which was signed into law by President Clinton on 26 April 1996. A very long and complex act, it has been described by one leading commentator as a ‘‘comprehensive charter of obstructions and disabilities designed to discourage prisoners from seeking legal redress’’ (Boston). The act contains restrictions on prisoner litigation that are not imposed on any other people who sue for violations of their rights.
A major thrust of the act limits the ability of the courts to enter injunctive relief, that is to order prison officials to do something or to stop doing something, to improve prison conditions. The act states that federal courts must not grant injunctive relief any greater than what is minimally necessary to correct the violations of law identified by the courts. In shaping the relief, the court has to give substantial weight to the impact of its relief on public safety or the operation of the criminal justice system.
The burgeoning prison populations spawned many overcrowding cases. The PLRA contains a specific provision governing release orders in overcrowding cases. No release order can be entered unless the court has previously tried a less restrictive remedy that has failed and the defendant prison officials are given a reasonable time period to comply with the orders of the court. No relief may be granted unless there is a finding that overcrowding is the primary cause of the violation of a federal right and no other relief will remedy the violation. Moreover, the named defendants or other government officials who have the responsibility to fund and operate and maintain the programs of the released prisoners or to prosecute them may intervene to oppose a release order. Accordingly, a broad variety of officials including district attorneys, local jail officials, and local politicians are eligible to participate formally in these proceedings— formidable opponents to prisoner actions.
Other limitations on the way in which courts have enforced constitutional rights in prison reform cases are contained in the PLRA. Special masters, who once played a major role in the cases, are now subject to new constraints including limitations on the hourly rate that they can be paid. Another provision provides a two-year ‘‘sunset period’’ on injunctive orders. Under this provision, the relief order is automatically terminated whether or not compliance has been achieved on the second anniversary of the issuance of the order unless the prisoners’ attorney again proves that constitutional violations are occurring.
The act provides that no consent decree can be entered that does not comply with certain spelled-out limitations. Consent decrees that go beyond the minimum necessary to correct the violation of the federal right in the least restrictive manner cannot be approved. Parties that do reach agreements without these findings cannot have these agreements enforced by the courts. Such agreements, called ‘‘Private Settlement Agreements,’’ can merely provide that in case of noncompliance, the plaintiff may restart the case.
The scores of existing consent decrees already entered in prison-conditions cases were subject to immediate termination unless the district court found retroactively that the stringent requirements of the act had been meet. The relief under the consent decree is automatically stayed thirty days following the filing of the motion to terminate the decree until the court rules on the motion. At the discretion of the court the thirty-day period can only be extended for an additional sixty days. This ninety-day maximum imposes an almost impossibly brief time on the district court to make findings necessary to continue the decree. If the timetable is not met, the consent decree will not be enforceable for the period needed to reach a decision.
The PLRA’s far-reaching provisions, which limit the powers of the federal courts to enforce the rights of prisoners, raise numerous constitutional issues. Lower courts found one aspect of the act, the automatic stay provision, unconstitutional (United States v. Michigan, 91 F.3d 144 (6th Cir. 1996), and Hadix v. Johnson, 933 F. Supp. 1362 (W.D. Mich. 1996)). However, in an important PLRA decision, Miller v. French, 120 S.Ct 2246 (2000), the Supreme Court upheld the automatic-stay provision. Writing for the fivemember majority, Justice O’Connor held that the automatic-stay provision of the PLRA did not violate the constitutional requirement of separation of powers.
Other evidence of the restrictive nature of the PLRA on prisoner suits and its deference to prison administration includes the exhaustion requirement, the ‘‘three strikes, you’re out’’ provision, and the physical injury requirement.
Under the exhaustion requirement, inmates may not sue in federal court until they have used all administrative remedies available to them. At first blush this may not seem unfair. However, it is questionable whether, in many cases, an inmate will receive a fair and complete hearing from a potentially hostile administration. Thus, the exhaustion requirement becomes a test of endurance and delay to which no other civil rights plaintiffs are subjected.
Perhaps the most draconian provision of the PLRA is the so-called ‘‘three strikes, you’re out’’ section which deprives an inmate of the right to litigate as a poor person (that is, the right of qualifying pro se plaintiffs to have court filing fees waived) after three previously dismissed actions. There is only one exception where the inmate is in imminent danger of physical injury. There are many reasons for dismissal of a case, beyond the fact that the claim is without merit. An inexperienced, uneducated pro se inmate plaintiff is as likely to have his case dismissed on procedural grounds of which he has little knowledge, as for legitimate legal reasons.
The PLRA also purports to limit recovery by providing that no federal civil action may be brought ‘‘for mental or emotional injury suffered in custody without a prior showing of physical injury.’’ Physical injury itself requires proof of resulting disease or other adverse consequences. The courts have eased the harshness of this provision by holding that the physical injury provision of the PLRA only applies to actions for mental or emotional injuries and not to claims of violations of constitutional rights that inflict injuries that are neither physical nor mental or emotional.
Balanced against the restrictions of the PLRA is the Civil Rights on Institutionalized Persons Act (the CRIPA), another act of Congress passed before the PLRA but not repealed by it. The CRIPA gives the Attorney General of the United States the authority to investigate conditions in prisons and jails and file suit or intervene in a pending action if a pattern or practice of unlawful actions by prison officials is found by the Attorney General to deprive inmates of their constitutional rights. The Attorney General has delegated day-to-day responsibility for enforcement of this Act to the Special Litigation Section of the Civil Rights Division of the Justice Department.
This act contains none of the restrictions that the PLRA imposed on private litigation. Thus, it allows the government to be a vigorous enforcer of the constitutional rights of inmates. However, this assumes that the government is controlled by politicians who place a value on the rights of inmates and who are willing to commit resources to the enforcement of those rights.
In the last administration, the Justice Department did use its authority under the act to some extent. In fiscal year 1997, for example, the Department reported activity under the act in cases involving 164 facilities in 30 states and the District of Columbia, as well as Puerto Rico, Guam, and the Virgin Islands. However, with two million people housed in thousands of prisons and jails throughout the United States that effort, while important, is not enough to realistically monitor and enforce the rights of all inmates.
Despite the cutbacks just described, we no longer live in a ‘‘hands off’’ era, nor are we likely to return to one in the future. Courts, even the Burger and Rehnquist Courts, have indicated time and again that the judiciary has an important watchdog role to play in ensuring that fundamental rights are not denied even to a group as politically powerless as prisoners. Yet, it is reasonable to wonder whether the courts and Congress went too far in cutting back on inmates’ rights in the 1980s and 1990s. The deference that is reflected in both the Supreme Court opinions and in the PLRA is unlike that given to any other department of government. Ironically, deference has been granted to the very institution that, because of its all-controlling nature, poses a greater risk of abuse than virtually any other institution of government. The opposition to the current deferential doctrine was well expressed by Justice Brennan who wrote that a high level of deference to prison officials is not justified. Justice Brennan explained, ‘‘The Constitution was not adopted as a means of enhancing the efficiency with which government officials conduct their affairs, nor as a blueprint for ensuring sufficient reliance on administrative expertise. Rather it was meant to provide a bulwark against infringements that might otherwise be justified as necessary expedients of governing’’ (O’Lone v. Estate of Shabbaz, 482 U.S. 342, 356).
In the years ahead, these factors might compel the courts and the legislative branch to extend greater protections to prisoners’ rights than is the case currently. With so many hundreds of thousands of Americans going into and coming out of prison every year, the well-being of the larger society demands no less.
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