University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Johnson v. Heffron JC-MI-0002
Docket / Court 79-45 ( W.D. Mich. )
State/Territory Michigan
Case Type(s) Jail Conditions
Case Summary
In 1979, the plaintiffs, pretrial detainees, filed a class action lawsuit in the U.S. District Court for the Western District of Michigan against the Kent County Sheriff and the Kent County Correctional Facility (KCCF). The plaintiffs, represented by Legal Aid of Western Michigan and private ... read more >
In 1979, the plaintiffs, pretrial detainees, filed a class action lawsuit in the U.S. District Court for the Western District of Michigan against the Kent County Sheriff and the Kent County Correctional Facility (KCCF). The plaintiffs, represented by Legal Aid of Western Michigan and private counsel, alleged that the jail conditions violated their constitutional rights under the First, Eighth, and Fourteenth Amendments. In the midst of this litigation, the District Court identified a ''woeful overpopulation" problem at KCCF, with an average daily population of

466 in 1982 in a facility rated for 451 occupants. The facility exceeded maximum capacity

for 332 days of that year.

In 1982, the parties agreed to a partial consent decree, addressing among other things the problem of overcrowding at KCCF. The consent decree required KCCF not to exceed 90% of maximum capacity. The consent decree was amended in 1985 to allow for 95% maximum capacity and to create procedures initiated when the jail population exceeded 95% capacity for three consecutive days.

In 1994 KCCF was fully renovated, increasing the total number of beds from 573 to 994. The defendants filed a motion to vacate the previous consent judgment. On March 20, 1995, the District Court (Judge Richard A. Enslen) denied the motion. The court held that, in neglecting to provide specific data about the overpopulation problem, the defendants had failed to show that the goals of the consent decree had been achieved.

In May 1995, the defendants made a renewed motion to vacate the consent judgment, this time supporting their motion with data showing that, since the 1994 renovation, KCCF had been under 95% capacity 98% of the time. The District Court again denied the defendants' motion. The court held that there was an insufficient buffer to assure that overcrowding would not again become a problem at KCCF if the consent decree was vacated. In addition, the court questioned the defendants' motivations for dissolving a capacity limit the defendants claimed would not be exceeded in the future. The defendants appealed.

On July 9, 1996, the Court of Appeals for the Sixth Circuit (Judge David A. Nelson) reversed and remanded, finding that the District Court had abused its discretion in denying the motion, citing the defendants' record of substantial compliance with the consent decree and their good faith efforts to improve conditions at KCCF. The court remanded for entry of relief from judgment. Johnson v. Heffron, 88 F.3d 404 (6th Cir. 1996).

On remand, the District Court granted the defendants' motion to vacate the consent decree on August 7, 1996.

The plaintiffs filed a motion for attorney's fees and costs; this was apparently settled by a stipulation, which was entered in the PACER docket on September 19, 1996.

Chris Sullivan - 08/26/2005


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Type of Facility
Government-run
Causes of Action 42 U.S.C. ยง 1983
Defendant(s) Kent County Correctional Facility
Plaintiff Description pretrail detainees in Kent County, Michigan
Indexed Lawyer Organizations None on record
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 1979 - 1996
Case Closing Year 1996
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)
79-45 (W.D. Mich.) 01/24/1979
JC-MI-0002-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Reported Opinion 07/09/1996 (88 F.3d 404)
JC-MI-0002-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Enslen, Richard Alan (W.D. Mich.)
JC-MI-0002-9000
Kennedy, Cornelia Groefsema (E.D. Mich., Sixth Circuit)
JC-MI-0002-0001
Monitors/Masters None on record
Plaintiff's Lawyers Archer, Robert W. (Michigan)
JC-MI-0002-9000
Meeks, John E. (Michigan)
JC-MI-0002-0001 | JC-MI-0002-9000
Nelson, Michael O. (Michigan)
JC-MI-0002-0001 | JC-MI-0002-9000
Defendant's Lawyers Decker, Teresa S. (Michigan)
JC-MI-0002-0001
DeWitt, Jon F. (Michigan)
JC-MI-0002-9000
Other Lawyers None on record

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