University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Wayne County Jail Inmates v. Wayne County Sheriff JC-MI-0005
Docket / Court NA ( State Court )
State/Territory Michigan
Case Type(s) Jail Conditions
Special Collection Court-ordered receiverships
Attorney Organization Legal Services/Legal Aid
Case Summary
In 1971, prisoners in the Wayne County Jail filed a class action in the Wayne County Circuit Court under 42 U.S.C. § 1983 against the Wayne County Sheriff. The prisoners were represented by the Legal Services of Michigan, and alleged violations of their rights under Federal and State ... read more >
In 1971, prisoners in the Wayne County Jail filed a class action in the Wayne County Circuit Court under 42 U.S.C. § 1983 against the Wayne County Sheriff. The prisoners were represented by the Legal Services of Michigan, and alleged violations of their rights under Federal and State constitutions, as well as state law for inhumane and barbaric conditions. Specifically, the plaintiffs alleged that failure of the jail to comply with Michigan law that related to building code, safety, and sanitary laws were a violation of their substantive due process rights.

After 13 months of lengthy hearings, a 3-judge Wayne County Circuit Court panel found that the conditions at the jail were deplorable and did violate the inmates' rights as claimed.

The panel entered detailed findings and an order that specified the manner in which the jail needed to be restored to a suitable condition. The panel also appointed a monitor to oversee the execution of its order. The defendants, while not disputing the trial court's findings or conclusions of law, argued that the trial court had exceeded its authority because the order violated the principle of the separation of powers. In 1973, the Michigan Supreme Court, in remanding the case, found that the trial court was authorized to enact such a specific order once it had been shown that the defendants had failed to meet their statutory duties. The court also held that the appointment of a monitor was appropriate, and the sua sponte joinder of additional defendants by the court was also appropriate.

In 1988, after 15 years of monitoring and noncompliance, the Wayne County Circuit Court appointed the Wayne County Executive as the receiver of the jail, removing the Sheriff's control. The Sheriff moved for disqualification of the judge and the entire Wayne County Circuit Court bench, but that motion was denied. The prisoners' motion for the appointment of a receiver was granted. The Sheriff appealed.

On July 26, 1989, the Michigan Court of Appeals (Judge Cynar) found that the Circuit Court had the authority to appoint a receiver, that such appointment was appropriate, and that the judges did not err by not disqualifying themselves.

We have no further information on this case.

Blase Kearney - 07/03/2012


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Issues and Causes of Action
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Issues
Content of Injunction
Monitor/Master
Receivership
Crowding
Crowding / caseload
Pre-PLRA Population Cap
General
Bathing and hygiene
Fire safety
Food service / nutrition / hydration
Recreation / Exercise
Sanitation / living conditions
Totality of conditions
Medical/Mental Health
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
42 U.S.C. § 1983
Defendant(s) Wayne County Jail
Plaintiff Description prisoners in the Wayne County Jail
Indexed Lawyer Organizations Legal Services/Legal Aid
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 not on record
Case Closing Year 1974
Case Ongoing Unknown
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 ]

  Wayne County Jail Inmates v. Wayne County Sheriff: The Anatomy of a Lawsuit
By: Marvin Zalman (Wayne State University)
Citation: 71 Prison J. 4 (1991)
[ Detail ]

Docket(s)
No docket sheet currently in the collection
General Documents
Opinion and Order 04/16/1974 (216 N.W.2d 910)
JC-MI-0005-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion (Michigan Court of Appeals) 07/26/1989 (444 N.W.2d 549)
JC-MI-0005-0001 PDF | WESTLAW| LEXIS | Detail
Judges Cynar, Walter P. (State Appellate Court)
JC-MI-0005-0001
Kavanaugh, Thomas G. (State Supreme Court)
JC-MI-0005-0002
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers None on record
Other Lawyers None on record

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