University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Stewart v. Gates JC-CA-0054
Docket / Court 2:75-cv-03075 ( C.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Special Collection California Jail Population Caps
Attorney Organization Hadsell, Stormer & Renick
Case Summary
In 1975, pretrial detainees in the Orange County Jail filed a lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the Central District of California, challenging the conditions of confinement at the Orange County Jail. Attorneys with the ACLU Foundation of Southern ... read more >
In 1975, pretrial detainees in the Orange County Jail filed a lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the Central District of California, challenging the conditions of confinement at the Orange County Jail. Attorneys with the ACLU Foundation of Southern California represented Plaintiffs.

In 1978, the District Court (Judge William P. Gray) found unconstitutional conditions of confinement at the jail and issued injunctive relief ordering reforms be implemented in a number of areas. including: telephone access, visitation, law library access, mail, religious exercise, administrative segregation, meals, and sleeping accommodations. Stewart v. Gates, 450 F. Supp. 583 (C.D. Cal. 1978), remanded by Stewart v. Gates, 618 F.2d 117 (9th Cir. 1980). Judge Gray awarded attorney fees to Plaintiffs' counsel, but the Ninth Circuit Court of Appeals reversed and remanded the case for recalculation of fees. Stewart v. Gates, 987 F.2d 1450 (9th Cir. 1993) (Circuit Judge Robert R. Beezer).

At some point during the 1980s, a population cap and other remedial orders were added. Other than the issue of fees, we have little information on case activity from 1980 to 2003, when memoranda were filed by the Court's ombudsman and Plaintiffs alleging violations of the Court's orders.

On March 11, 2004, the District Court (Judge Gary L. Taylor) consolidated the case with Pierce v. County of Orange, No. 8:01-cv-00981 [JC-CA-0046]. On April 27, 2005, relying upon the 1996 Prison Litigation Reform Act and case law emphasizing prison administrators discretion, Judge Taylor vacated the previously entered remedial orders and dismissed the case.

Plaintiffs appealed, and on March 23, 2008, the U.S. Court of Appeals for the Ninth Circuit (Judge Betty B. Fletcher) partially reversed the district court's decision, ruling that the district court could not terminate its previous orders securing minimal access to religious services and exercise. The Court of Appeals also ruled that the County was in violation of the ADA because of disparate programs and services that were offered to disabled versus non-disabled inmates. The case was remanded for further fact-finding on the state of physical barriers to adequate access to bathrooms, showers, exercise areas, dayrooms, dining rooms, cells and all other areas to which disabled persons should have access, and to order remedial remedies as required.

On January 7, 2011, after a six-day bench trial, the Court (Judge Audrey B. Collins) confirmed the ADA sub-class as pretrial detainees with either a "mobility" or "dexterity" impairment, and made detailed findings of fact as to the conditions in the various facilities. After the parties offered proposed plans and comments, the Court entered judgment for the plaintiffs on June 28, 2011, accepting the defendant's final proposed plan for addressing the physical barriers identified in the factual findings and ensuring that disabled detainees were provided with equal access to programs, services, and activities as discussed therein.

Over the next year, the parties fought over attorneys' fees and issues regarding the Orange County Jail's compliance with the judgment. On February 10, 2014, Judge Collins terminated the ongoing order and injunctive relief, having found that the injunction was no longer necessary because the three areas in which plaintiffs sought to extend the injunction did not present current or ongoing violations and thus continued monitoring was no longer necessary.

Timothy Shoffner - 07/06/2012


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
Crowding
Crowding / caseload
Pre-PLRA Population Cap
Defendant-type
Corrections
General
Administrative segregation
Law library access
Mail
Phone
Recreation / Exercise
Religious programs / policies
Search policies
Visiting
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Board of Supervisors of the County of Orange
Orange County Sheriff's Department
Plaintiff Description Prisoners of the Orange County Central Jail challenging policies and practices of administrators of jail.
Indexed Lawyer Organizations Hadsell, Stormer & Renick
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1978 - 2014
Case Closing Year 2014
Case Ongoing No
Case Listing JC-CA-0046 : Pierce v. Orange County (C.D. Cal.)
JC-CA-0078 : Benson v. County of Orange (C.D. Cal.)
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
2:75-cv-03075-GLT (C.D. Cal.) 02/10/2014
JC-CA-0054-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Memorandum of Decision 05/03/1978 (450 F.Supp. 583) (C.D. Cal.)
JC-CA-0054-0009 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
[Ninth Circuit] Opinion [Reversing and Remanding the District Court's Award of Attorneys' Fees] 03/12/1993 (987 F.2d 1450)
JC-CA-0054-0004 PDF | WESTLAW| LEXIS | Detail
Order Vacating Earlier Orders and Dismissing Case 04/27/2005 (C.D. Cal.)
JC-CA-0054-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Amended [Ninth Circuit] Opinion [Affirming the Termination of All but Two of the Extant Orders] 05/15/2008 (526 F.3d 1190)
JC-CA-0054-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order [Regarding] Preliminary Trial Issues 05/07/2010 (C.D. Cal.)
JC-CA-0054-0003 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Findings of Fact and Conclusions of Law [Ordering the County to Remedy ADA Violations] 01/07/2011 (761 F.Supp.2d 915) (C.D. Cal.)
JC-CA-0054-0006 PDF | WESTLAW| LEXIS | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order on Defendant's Amended Final Plan Submitted Pursuant to the Court's June 27, 2011 Order 06/28/2011 (C.D. Cal.)
JC-CA-0054-0007 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order Re Amendments to Clarify Language in the Court's June 28, 2011 Final Order on Defendant's Proposed Plan 07/30/2012 (C.D. Cal.)
JC-CA-0054-0008 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Beezer, Robert R. (Ninth Circuit)
JC-CA-0054-0004
Collins, Audrey B. (C.D. Cal.)
JC-CA-0054-0003 | JC-CA-0054-0006 | JC-CA-0054-0007 | JC-CA-0054-0008 | JC-CA-0054-9000
Fletcher, Betty Binns (Ninth Circuit)
JC-CA-0054-0002
Gray, William Percival (C.D. Cal., S.D. Cal.)
JC-CA-0054-0009
Taylor, Gary L. (C.D. Cal.)
JC-CA-0054-0001
Monitors/Masters None on record
Plaintiff's Lawyers Baltodano, Hernaldo J. (California)
JC-CA-0054-9000
Herman, Richard P. (California)
JC-CA-0054-9000
Jakes, Jill (California)
JC-CA-0054-0009
Keeny, Christy Virginia (California)
JC-CA-0054-9000
Litt, Barrett S. (California)
JC-CA-0054-9000
Miller, Bryan Barnet (California)
JC-CA-0054-9000
Okrand, Fred (California)
JC-CA-0054-0009
Smerling, Terry (California)
JC-CA-0054-0009
Stormer, Dan Lewis (California)
JC-CA-0054-9000
Defendant's Lawyers Choi, Jin S (California)
JC-CA-0054-9000
Golden, Jack W. (California)
JC-CA-0054-9000
Kuyper, Adrian (California)
JC-CA-0054-0009
Lawrence, David D. (California)
JC-CA-0054-0007 | JC-CA-0054-9000
Miller, Steven C. (California)
JC-CA-0054-9000
Phillips, Wendy J. (California)
JC-CA-0054-9000
Sprenger, Christina M. (California)
JC-CA-0054-0007 | JC-CA-0054-9000
Wahlstedt , Arthur C. (California)
JC-CA-0054-0009
Other Lawyers None on record

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