Supreme Court of the United States
Brown v. Plata
May 23, 2011563 U.S. 493
Summary
The Supreme Court affirmed a three-judge district court's order requiring California to reduce its prison population to 137.5% of design capacity within two years, holding that the Prison Litigation Reform Act authorizes the relief and that the population limit is necessary to remedy longstanding Eighth Amendment violations in the provision of medical and mental health care that severe overcrowding perpetuates. The Court upheld the convening of the three-judge court, the findings that crowding is the primary (though not sole) cause of the violations and that no other relief would remedy them, the order's narrow tailoring despite collateral effects and systemwide scope, and the substantial weight given to public safety, while stressing that the cap was set to release the fewest prisoners consistent with an efficacious remedy and that the decree remains open to modification, including a possible deadline extension upon appropriate preconditions. Justice Scalia, joined by Justice Thomas, dissented, arguing the injunction rests on an untenable theory of systemwide unconstitutionality, violates the PLRA, and exceeds the proper role of federal courts; Justice Alito, joined by Chief Justice Roberts, dissented, arguing the three-judge court relied on outdated evidence, ignored less drastic remedies, and failed to give real weight to public safety.
Holding
- Whether the Supreme Court has jurisdiction under 28 U.S.C. §1253 to review the merits of the decision to convene the three-judge court.. Yes. Exercising its §1253 jurisdiction, the Court may determine the authority of the court below, including whether the three-judge court was properly constituted; the merits of the convening decision are properly before it.
- Whether the PLRA's previous-order and reasonable-time prerequisites for convening a three-judge court were satisfied.. Yes. The previous-order requirement was met by the 1995 appointment of the Coleman Special Master and the 2002 Plata consent decree and stipulated injunction; the reasonable-time requirement did not oblige the district courts to give still more time to later, substantially similar remedial efforts, because reasonableness is assessed in light of the entire history of remedial efforts.
- Whether the three-judge court erred in finding that crowding is the primary cause of the constitutional violations, including its admission of evidence of current prison conditions.. No. Crowding is the 'primary cause' within the meaning of §3626(a)(3)(E)(i) because it is the foremost, chief, or principal cause—not the sole cause—and the court properly admitted, cited, and considered evidence of current conditions; its discovery cutoff and exclusion of merits-only evidence were within its sound discretion.
- Whether clear and convincing evidence supported the finding that no other relief would remedy the violations.. Yes. Out-of-state and county-facility transfers are themselves population limits under §3626(g)(4), not less restrictive alternatives; the record showed no realistic possibility that new construction, additional hiring, or continued Receiver and Special Master efforts would remedy the violations absent a population reduction.
- Whether the population-limit order is narrowly drawn, extends no further than necessary, and is the least intrusive means of correcting the violation despite collateral effects and systemwide scope.. Yes. A narrow and otherwise proper remedy is not invalid merely because it will have collateral effects; the order gives the State flexibility to choose who is released and how to comply, and its systemwide scope matches the systemwide violations found in Coleman and stipulated in Plata, with facilities free to exceed 137.5% so long as the system as a whole complies.
- Whether the three-judge court gave substantial weight to any adverse impact on public safety.. Yes. The PLRA's substantial-weight requirement does not require certification that an order has no possible adverse impact on the public; the court devoted nearly ten days of trial to public safety, credited statistical evidence that population reductions elsewhere did not harm public safety, and structured the order to mitigate risk by leaving implementation choices to state officials.
Docket 09-1233