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Case Name Doty v. County of Lassen JC-CA-0076
Docket / Court 2:89-cv-01019 ( E.D. Cal. )
State/Territory California
Case Type(s) Disability Rights-Pub. Accom.
Jail Conditions
Special Collection California Jail Population Caps
Attorney Organization Hadsell, Stormer & Renick
Prisoners Rights Union
Case Summary
On July 25, 1989, prisoners at the old Lassen County Jail ("Old Jail") filed a class action lawsuit in the U.S. District Court for the Eastern District of California against the County of Lassen and the Sheriff of the County of Lassen. The plaintiffs, represented by the Prisoner Rights Union and ... read more >
On July 25, 1989, prisoners at the old Lassen County Jail ("Old Jail") filed a class action lawsuit in the U.S. District Court for the Eastern District of California against the County of Lassen and the Sheriff of the County of Lassen. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging that conditions in the Old Jail violated the First, Fourth and Eighth Amendments of the Constitution of the United States as applied to the states through the Fourteenth Amendment. Among other things, they alleged overcrowding, inadequate clothing, inadequate medical, dental and mental health care, inadequate privacy for conversations with attorneys, and unequal access to programs for women prisoners. Plaintiffs sought a broad set of injunctive remedies.

When the suit was filed, Lassen County was developing and implementing plans for construction of a new, much larger jail ("New Jail").

On October 17, 1989, the District Court approved a stipulated order preliminarily enjoining certain Old Jail conditions. Pursuant to the stipulated order, the County agreed to: (1) limit inmate population at the Old Jail to forty-one inmates; (2) limit the temporary holding cell's population to the rated capacity; (3) limit time spent in the temporary holding cell to eight hours; (4) comply with California law in its use of the detoxification facility; (5) provide all prisoners with a permanent bed appropriate to his/her classification; and (6) provide all prisoners with daily access to the "program room" and outdoor recreation.

Beginning on July 16, 1990, the case was tried before Magistrate Judge John F. Moulds. The trial concluded in September 1990. On July 1, 1991, the New Jail opened and the County ceased using the Old Jail.

On August 1, 1991, Magistrate Judge Moulds entered his 129-page findings and recommendations. On September 17, 1991, District Judge Lawrence K. Karlton entered an order adopting the findings and recommendations, with one minor modification. The order granted the following relief: (1) For a period of one year, the County was prohibited from exceeding the established inmate capacities at the Old Jail or the New Jail; (2) The County was required to "modify" and follow written policies regarding access to the jail law library; (3) The County was required to clarify the procedures for staff handling of prisoners demonstrating a mental disorder; (4) The County was required to develop a procedure for ensuring a timely response to an inmate's request for mental health care. All further requests for relief were denied. On October 9, 1991, Judge Karlton entered a judgment. On November 7, 1991, the defendants filed their notice of appeal from the judgment.

The attorney's fees litigation then commenced, with both sides seeking attorney's fees. On March 30, 1993, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue. On April 20, 1993, Judge Karlton filed an order adopting the finding and recommendations in full. This order granted the plaintiffs some of the attorney's fees they had sought, for a total of $219,027.61, and denied the defendants' request for fees. On April 27, 1993, Judge Karlton entered his Judgment pursuant to the attorney's fees order. On April 28, 1993, the appellants filed their notice of appeal from the attorney's fees order, and the award was stayed pending appeal.

On October 6, 1994, a three-judge panel of the Ninth Circuit (Circuit Judges Arthur L. Alarcon and Ferdinand F. Fernandez and District Judge Stephen V. Wilson, sitting by designation) reversed the District Court's decision to grant permanent injunctive relief but affirmed its decision that attorney's fees were appropriate. Doty v. Cnty. of Lassen, 37 F.3d 540 (9th Cir. 1994). The panel, in an opinion by Judge Wilson, found that the injunction as a whole was erroneous because there was no evidence of constitutional violation at the New Jail. It also found, however, that since the plaintiffs had succeeded in obtaining a preliminary injunction and had catalyzed other reforms at the jails, they were "prevailing parties" under 42 U.S.C. § 1988 and could be awarded reasonable attorney's fees; it therefore vacated the District Court's award and remanded for redetermination in light of plaintiffs' limited success.

On remand, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue on July 26, 1995, and Judge Karlton adopted them in full on September 19, awarding plaintiffs a total of $83,616.75. On the same day, Judge Karlton entered judgment in favor of the defendants per the order of the Court of Appeals.

(This summary is adapted in part from the Appeals Court's discussion of the background of the case. See Doty, 37 F.3d at 542.)

Christopher Schad - 07/11/2012


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Freedom of speech/association
Unreasonable search and seizure
Crowding
Crowding / caseload
Pre-PLRA Population Cap
Defendant-type
Corrections
Disability
Mental impairment
Discrimination-basis
Disability (inc. reasonable accommodations)
Sex discrimination
General
Access to lawyers or judicial system
Bathing and hygiene
Conditions of confinement
Food service / nutrition / hydration
Grievance Procedures
Law library access
Record-keeping
Recreation / Exercise
Staff (number, training, qualifications, wages)
Medical/Mental Health
Medical care, general
Mental health care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) County of Lassen
Plaintiff Description prisoners in the Lassen County jails
Indexed Lawyer Organizations Hadsell, Stormer & Renick
Prisoners Rights Union
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
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1989 - 1994
Case Closing Year 1994
Case Ongoing No
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)
2:89−cv−01019 (E.D. Cal.) 03/12/1996
JC-CA-0076-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Injunctive Relief Class Action 06/25/1989
JC-CA-0076-0002 PDF | Detail
Document Source: District Court
Findings and Recommendations 09/12/1991 (E.D. Cal.)
JC-CA-0076-0003 PDF | Detail
Document Source: District Court
Order 09/18/1991 (E.D. Cal.)
JC-CA-0076-0004 PDF | Detail
Document Source: District Court
Judgment in a Civil Case 10/09/1991 (E.D. Cal.)
JC-CA-0076-0006 PDF | Detail
Document Source: District Court
[Ninth Circuit] Opinion [Vacating the District Court's Injunction] 10/06/1994 (37 F.3d 540)
JC-CA-0076-0001 PDF | WESTLAW| LEXIS | Detail
Judges Karlton, Lawrence K. (E.D. Cal.)
JC-CA-0076-9000
Moulds, John F. (E.D. Cal.) [Magistrate]
JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-9000
Wilson, Stephen Victor (C.D. Cal.)
JC-CA-0076-0001
Monitors/Masters None on record
Plaintiff's Lawyers Abbott, Harold L. (California)
JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Berry, Gina S. (California)
JC-CA-0076-9000
Comiskey, Paul Wayne (California)
JC-CA-0076-0002 | JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Derevan, Richard (California)
JC-CA-0076-9000
Eisen, Jay-Allen (California)
JC-CA-0076-9000
Fabricant, Deborah (California)
JC-CA-0076-9000
Herman, Richard P. (California)
JC-CA-0076-0002 | JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Persons, Paul Turner (California)
JC-CA-0076-0002 | JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Stormer, Dan Lewis (California)
JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Defendant's Lawyers Franklin, Roberta L. (California)
JC-CA-0076-0003 | JC-CA-0076-0004 | JC-CA-0076-0006 | JC-CA-0076-9000
Woodlock, Lawrence T. (California)
JC-CA-0076-9000
Other Lawyers None on record

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