University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Harris v. County of Placer JC-CA-0081
Docket / Court 2:90-cv-00394 ( E.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Special Collection California Jail Population Caps
Attorney Organization Hadsell, Stormer & Renick
Prisoners Rights Union
Case Summary
On March 29, 1990, several prisoners in the Placer County jail system filed a lawsuit in the U.S. District Court for the Eastern District of California against Placer County. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging ... read more >
On March 29, 1990, several prisoners in the Placer County jail system filed a lawsuit in the U.S. District Court for the Eastern District of California against Placer County. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging unconstitutional conditions of confinement and, in particular, overcrowding. They sought declaratory and injunctive relief.

On July 20, 1990, the District Court (Senior Judge Thomas J. Macbride) issued a preliminary injunction regarding prisoner population capacities at the Placer County Jail. The injunction was amended on August 17, 1990, by Judge Lawrence K. Karlton and Magistrate Judge John F. Moulds; the content of the amendment is unclear from the docket.

The docket also contains few entries for the following two years; presumably, the parties were negotiating a settlement, as Magistrate Judge Peter A. Nowinski notified the court that the case had settled on July 24, 1992. Under the terms of the settlement, the defendants agreed, among other things, to a population cap of 100 percent capacity at the Placer County Mail Jail and Minimum Security facilities (646 people). To make this feasible, the settlement also authorized the sheriff to begin releasing prisoners when a facility is within ten percent of its rated capacity.

Following notice to the settlement class, Magistrate Judge Nowinski made a report and recommendation to the Court that the settlement should be approved, with the exception of a provision regarding the jail's "safety cell."

On April 16, 1993, the Court (Judge Karlton) adopted the magistrate's recommendation in full, and the settlement was approved.

The settlement was still in effect as of 2008, when the sheriff sent a letter to the Placer County Board of Supervisors informing the Board that it had released prisoners under the District Court's order every day of the last fiscal year and asking it to approve alternative sentencing programs to lighten its load.

Christopher Schad - 07/18/2012


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Pre-PLRA Population Cap
Defendant-type
Corrections
General
Conditions of confinement
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) County of Placer
Plaintiff Description prisoners at the Placer County Main Jail and Minimum Security facilities
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 Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1993 - n/a
Case Closing Year n/a
Case Ongoing Yes
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)
2:90-cv-00394-LKK-PAN (E.D. Cal.) 04/16/1993
JC-CA-0081-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
[Letter from the Sheriff to the County Board of Supervisors Regarding a] Resolution to Authorize Expansion of Alternative Sentencing Programs 08/05/2008
JC-CA-0081-0001.pdf | Detail
Judges Karlton, Lawrence K. (E.D. Cal.)
JC-CA-0081-9000
Nowinski, Peter A. (E.D. Cal.) [Magistrate]
JC-CA-0081-9000
Monitors/Masters None on record
Plaintiff's Lawyers Comiskey, Paul Wayne (California)
JC-CA-0081-9000
Herman, Richard P. (California)
JC-CA-0081-9000
Persons, Paul Turner (California)
JC-CA-0081-9000
Stormer, Dan Lewis (California)
JC-CA-0081-9000
Defendant's Lawyers Carden, Gerald O'Brien (California)
JC-CA-0081-9000
Hagar, John H. Jr. (California)
JC-CA-0081-9000
Other Lawyers None on record

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