Case: Johnson v. O'Brien and Bullington v. Moreland

On May 30, 1979, Robert Burlington, a pre-trial detainee at St. Louis County Jail in Clayton, Missouri, filed a lawsuit in the United States District Court for the Eastern District of Missouri against St. Louis County officials regarding conditions at the jail. The lawsuit was filed on behalf of all pre-trial detainees at the St. Louis County Jail. Burlington filed the lawsuit pro se.

In 1980, this case was consolidated with a previous lawsuit filed in 1976. That lawsuit, Johnson v. O'Brien, resulted in a December 30, 1977, order by District Judge John Nangle. Johnson v. O'Brien, 445 F. Supp. 122 (E.D. Mo. 1977). Judge Nangle ordered St. Louis County to complete renovations and alterations of the jail within one year from the date of the order. These renovations were to result in larger living areas for inmates. The district court also enjoined the number of inmates who could be housed at the jail prior to the renovations. The court ordered the jail to improve medical care, conduct a daily medical survey of inmates, allow inmates to clean their living areas and launder their clothes, and allow regular visitation. Judge Nangle's 1980 consolidation of the two cases aimed to determine the defendants' compliance with the 1977 order.

Mr. Burlington's initial pleading was a petition for temporary injunction. He claimed that jail officials were violating his First and Fourteenth Amendment Rights by not allowing him access to periodicals he received in the mail. In August 1979, other inmates petitioned the court to participate in the lawsuit and claimed numerous other constitutional violations, including overcrowding, unsanitary conditions, lack of recreation, denial of visitation rights, and inadequate medical care. An amended complaint was filed after the plaintiffs obtained representation by private attorneys, incorporating many of the inmates' claims. In February 1980, the district court approved the case as a class action, adopting a January 10, 1980, recommendation to that effect by U.S. Magistrate David D. Noce. Magistrate Judge Williams S. Bahn conducted a review of jail conditions, including a personal visit to the jail, and stated in an unpublished July 1980, order that he had determined that, in most areas, the jail was in compliance with the previous order. There was overcrowding and the facility lacked a proper library, however.

The parties subsequently came to agreement on many of the issues in the complaints. Their stipulation, dated August 12, 1983, reaffirmed the Johnson v. O'Brien order and set out the defendants' agreement to implement population limits, provide additional material in the law library, cease conducting strip searches in connection with visitation privileges, and segregate pre-trial detainees under the age of sixteen years. Judge Nangle ordered the stipulation posted in the jail. Litigation continued concerning attorneys' fees, with the two appointed counsel for plaintiffs receiving fee awards of $25,000 and $12,500, respectively, pursuant to Judge Nangle's November 29, 1983, unpublished order.

On August 2, 1993, due to flooding at another jail and the subsequent transfer of inmates to the St. Louis County Jail, the district court temporarily lifted the population limits in the jail. This emergency order was terminated on March 29, 1994, upon the defendants' request, by an unpublished order by District Judge Edward L. Filippine. The docket does not indicate any further litigation in this case.