University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Castillon v. Correction Corporation of America PC-ID-0009
Docket / Court 1:12-cv-00559 ( D. Idaho )
State/Territory Idaho
Case Type(s) Prison Conditions
Case Summary
On November 9, 2012, 8 inmates at Idaho Correction Correctional Center filed a lawsuit through private counsel against Corrections Corporation of America (CCA), which operates the facility. The Plaintiffs had been the victims of a gang assault in which 6 members from the Aryan Knights and the ... read more >
On November 9, 2012, 8 inmates at Idaho Correction Correctional Center filed a lawsuit through private counsel against Corrections Corporation of America (CCA), which operates the facility. The Plaintiffs had been the victims of a gang assault in which 6 members from the Aryan Knights and the Severely Violent Criminals hid in a closet in order to attack the Plaintiffs with shivs and shanks. Plaintiffs alleged that CCA was using gang violence as a way to gain control over the inmate population and decrease the operating costs. Specifically, Plaintiffs alleged that CCA's operating practices, which included housing members of the same gang in the same block (creating what prisoners call a gang-controlled walk), operating at or above maximum capacity, and using insufficient numbers of guards, created a substantial risk of harm to inmates in the form of gang violence, pressure to join gangs, and pressure to participate in gang activities in and outside of the prison. Plaintiffs filed suit under 42 U .S.C. §1983 for violation of their 8th and 14th amendment rights under the color of state law and sought compensatory damages, punitive damages, and attorneys' fees. Plaintiffs also sought whatever injunctive relief the court might deem appropriate. Pictures, video of the attack, and other documents can be found on the Plaintiff's lawyers' website.

On January 18, 2013, Plaintiffs filed an amended complaint as a result of an anonymous email from a member of prison staff that alleged that the CCA had been falsifying its records to make it appear that the various blocks were fully staffed and in compliance with a settlement agreement from a previous case, Kelly v. CCA (Clearinghouse code: PC-ID-0007).

On February 8, 2013, CCA filed a motion to stay discovery and to dismiss the case for failure to state a claim and for failure to exhaust administrative remedies, claiming that 6 of the 8 inmates had not completed the full grievance procedure. On March 1, 2013, CCA filed a motion for a protective order to avoid discovery until the court rendered its decision on the motions to stay and to dismiss.

The Court (Judge Edward J. Lodge) denied the motion to stay and the motion for a protective order on April 19, 2013. 2013 WL 2446480 (D. Idaho 2013). CCA then filed a motion for a protective order to keep certain information confidential (personal identifying information for staff, criminal, medical, and institutional records of inmates, security sensitive policies, procedures, and reports).

On June 4, 2013, the Court dismissed the claims of two of the inmates, but ruled that irregularities in the grievance process and the assistant warden's approval of the response that "If you would like to pursue [compensation], you can do so utilizing outside sources." made the six remaining inmates' partial exhaustion of the grievance process sufficient to meet the requirements of the Prison Litigation Reform Act of 1995 (42 U.S.C. § 1997e, et seq.), and thus they were allowed to proceed. The Court also held that, despite what it considered to be exaggerations in the complaint, the Plaintiffs had stated a plausible claim for relief based on the ghost worker allegation and gang member placement.

A collection of Associated Press news organizations filed a motion to intervene in the proceedings so that it could oppose CCA's proposed protective order on the grounds that it would interfere with the press's ability to gather and report news.

As of this writing the docket shows no further development and the case is ongoing.

Kenneth Gray - 07/10/2013


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Conditions of confinement
Failure to discipline
Staff (number, training, qualifications, wages)
Unconstitutional conditions of confinement
Plaintiff Type
Private Plaintiff
Type of Facility
Non-government for profit
Causes of Action 42 U.S.C. § 1983
Defendant(s) Corrections Corporation of America
Plaintiff Description Eight inmates at Idaho Correction Correctional Center who had been the victims of a gang-planned assault with shivs and shanks carried out by six inmates from the Aryan Knights and the Severely Violent Criminals
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party None Yet / None
Public Int. Lawyer No
Nature of Relief None yet
Source of Relief None yet
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Links Inmates v. CCA in Idaho
Angstman, Johnson, and Associates
Posted: Jul. 10, 2013
By: Angstman Johnson
[ Detail ] [ External Link ]

Docket(s)
1:12-cv-559 (D. Idaho) 03/04/2013
PC-ID-0009-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Damages, and for Declaratory and Injunctive Relief 11/09/2012
PC-ID-0009-0001.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
First Amended Complaint for Damages, and for Declaratory and Injunctive Relief 01/18/2013
PC-ID-0009-0002.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Order 04/19/2013 (2013 WL 2446480) (D. Idaho)
PC-ID-0009-0003.pdf | WESTLAW | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order 06/04/2013 (D. Idaho)
PC-ID-0009-0004.pdf | Detail
Document Source: PACER [Public Access to Court Electronic Records]
Judges Lodge, Edward J. (D. Idaho)
PC-ID-0009-0003 | PC-ID-0009-0004 | PC-ID-0009-9000
Williams, Mikel H. (D. Idaho) [Magistrate]
PC-ID-0009-9000
Monitors/Masters None on record
Plaintiff's Lawyers Angstman, Thomas J. (Idaho)
PC-ID-0009-0001 | PC-ID-0009-0002 | PC-ID-0009-9000
Johnson, Wyatt Benton (Idaho)
PC-ID-0009-0002 | PC-ID-0009-9000
Smith, Nikki Rachelle (Idaho)
PC-ID-0009-0002 | PC-ID-0009-9000
Defendant's Lawyers Naylor, Kirtlan G. (Idaho)
PC-ID-0009-9000
Stoll, James R. (Idaho)
PC-ID-0009-9000
Struck, Daniel Patrick (Arizona)
PC-ID-0009-9000
Zoellner, Tara B. (Arizona)
PC-ID-0009-9000
Other Lawyers None on record

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