A class of prisoners brought this civil rights lawsuit in the U.S. District Court of the Northern District of California on December 1, 1978, against the City and County of San Francisco challenging the conditions of their confinement. More particularly, plaintiffs were objecting to the population level at San Francisco's jail on the sixth floor of the Hall of Justice ("Jail No. 1"). Plaintiffs were represented by several counsel, including the Equal Rights Advocates, Inc., in San Francisco.
The parties entered into a consent decree on July 15, 1982, requiring that the Jail's housing areas would not regularly house more inmates than the capacity set by the California Board of Corrections. In June, 1985, the plaintiffs moved to hold the City in contempt for violating the population level provision of the consent decree; the district court ordered the City to comply. After continued noncompliance, the district court allowed the City a period of time to present a plan for addressing the problem of overcrowding and appointed a Special Master (Allen F. Breed) to make recommendations. In August, 1987, the City agreed that the district court could impose monetary sanctions if it failed to comply with the consent decree. The court also granted special powers to the Sheriff, including the ability to release prisoners before they had served their full term, in order to meet the capacity level limits. Over the course of the next year, the district court expanded these powers of the Sheriff, but overcrowding continued. After allowing the City ample time to comply, the court ordered fines of $300 per inmate per day if the city failed to comply by March 15, 1989. The City complied by this date, and the district court extended the consent decree beyond its seven-year term and denied the pending contempt motion.
On December 17, 1991, after months of chronic overcrowding at Jail No. 1, the district court found the City in contempt, required immediate compliance, and imposed sanctions of $300 per day per inmate for each day after January 1, 1992, that the City violated the order. The court also expanded the Sheriff's powers for early release. The City filed a motion for stay of the order and reconsideration of the court's opinion; the District Attorney for the City filed an amicus brief urging invalidation of the portion of the court order that allowed the Sheriff to override state law and criminal sentences by releasing prisoners before they had completed their full sentence, citing federalism concerns.
The Court of Appeals for the Ninth Circuit (Judge Herbert Young Cho Choy) affirmed the contempt order, relying on two factors found by the district court: 1) the city's history of noncompliance with the population limits, and 2) the failure to comply despite the pendency of the contempt motion. Stone v. City & Co. of San Francisco, 968 F.2d 850 (9th Cir. 1992). Neither the City's intent to comply nor the financial constraints of compliance were defenses.
The Ninth Circuit further found that federal courts have very broad remedial powers, and that in certain situations, a federal court is justified in employing the early-release and state-law-override mechanisms. The Ninth Circuit found that the district court's original grants of early-release and state-law-override powers to the sheriff did not present federalism concerns, but that the subsequent expansion of these powers did. The district court had not made any finding that other alternatives were inadequate before it authorized this. Therefore, that portion of the order allowing the Sheriff to override applicable state law in conducting early release was vacated, and the rest of the order affirmed.
The United States District Court for the Northern District of California (Judge William Horsley Orrick, Jr.) ruled on January 19, 1993, that the fines imposed as part of the contempt order did not accrue during the period in which the contempt order was stayed pending appeal. Stone v. City and Co. of San Francisco, 145 F.R.D. 553 (N.D.Cal. 1993).
According to the docket on PACER, subsequent litigation included disputes over attorney's fees and the defendants' overcrowding plan. On December 20, 1996, the U.S. District Court for the Northern District of California (Judge Orrick) terminated the consent decree and dismissed the case with prejudice. An appeal was filed, but dismissed on January 22, 1997.Megan Raynor - 02/05/2006