University of Michigan Law School
Civil Rights Litigation Clearinghouse
new search
page permalink
Case Name Brenneman v. Madigan JC-CA-0001
Docket / Court C-70 1911 ( N.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Attorney Organization Legal Services/Legal Aid
Case Summary
On September 8, 1970, five pretrial detainees filed a lawsuit in the U.S. District Court for the Northern District of California under 42 U.S.C. § 1983, on behalf of themselves and all others awaiting trial in the Greystone section of the Santa Rita Rehabilitation Center in California. The named ... read more >
On September 8, 1970, five pretrial detainees filed a lawsuit in the U.S. District Court for the Northern District of California under 42 U.S.C. § 1983, on behalf of themselves and all others awaiting trial in the Greystone section of the Santa Rita Rehabilitation Center in California. The named defendants were the Sheriff and the members of the Board of Supervisors of Alameda County where the facility was located. The plaintiffs claimed that conditions at the facility were cruel and unusual punishment in violation of their 14th Amendment rights. After the judge visited the facility, on March 11, 1971, the court instructed the defendants to take whatever steps necessary to alleviate the cruel and unusual conditions of confinement at Greystone. The defendants made regular reports to the court regarding their progress over the next year.

On May 12, 1972, the U.S. District Court for the Northern District of California (Judge Alfonso Zirpoli) ruled that the conditions of confinement at Greystone violated the Due Process and Equal Protection rights of pretrial detainees. Brenneman v. Madigan, 343 F.Supp. 128 (N.D. Cal. 1972). The court found that the proper analysis for pretrial detainees was under the 14th Amendment rather than the 8th Amendment because they had not yet been found guilty of any crime. The court stated that the only valid interest the state possessed in restricting the liberty of the pretrial detainees was in ensuring their presence in court. The court found that administrative costs and expedience were not compelling reasons for violating the plaintiffs rights. The court ordered that the defendants not hold pretrial detainees continuously in cells, that the defendants offer activities for the pretrial detainees, that the pretrial detainees have access to phones for a large amount of time and that the pretrial detainees be allowed to visit as may people as they wish for more than 15 minutes per week. The parties were ordered to keep reporting to the court regarding their progress and the defendants were ordered to file a proposed set of rules for the treatment of pretrial detainees with the court within 90 days.

Jaclyn Adams - 02/20/2006


compress summary

- click to show/hide ALL -
Issues and Causes of Action
click to show/hide detail
Issues
Content of Injunction
Reporting
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Access to lawyers or judicial system
Conditions of confinement
Mail
Phone
Recreation / Exercise
Sanitation / living conditions
Totality of conditions
Visiting
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Alameda County
Plaintiff Description pretrial detainees awaiting trial in the Greystone section of the Santa Rita Rehabilitation Center in California
Indexed Lawyer Organizations Legal Services/Legal Aid
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
Form of Settlement None on record
Order Duration 1972 - n/a
Case Closing Year n/a
Case Ongoing Unknown
Additional Resources
click to show/hide detail
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)
No docket sheet currently in the collection
General Documents
Reported Opinion 05/12/1972 (343 F.Supp. 128) (N.D. Cal.)
JC-CA-0001-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Zirpoli, Alfonso Joseph (N.D. Cal.)
JC-CA-0001-0001
Monitors/Masters None on record
Plaintiff's Lawyers Berg, Richard (California)
JC-CA-0001-0001
Defendant's Lawyers Booty, Kelvin H. Jr. (California)
JC-CA-0001-0001 | JC-CA-0001-0001
Fennone, Thomas J. (California)
JC-CA-0001-0001 | JC-CA-0001-0001
Moore, Richard J. (California)
JC-CA-0001-0001 | JC-CA-0001-0001
Other Lawyers None on record

- click to show/hide ALL -

new search
page permalink

- top of page -