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Case Name Hudler v. Duffy JC-CA-0016
Docket / Court No. 404148 ( State Court )
State/Territory California
Case Type(s) Jail Conditions
Case Summary
In two consolidated cases, San Diego County inmates brought suit in state court challenging overcrowding conditions at five detention facilities: the Las Colinas Detention Facility for Women, El Cajon, South Bay, Vista and Descanso detention facilities. Hudler v. Duffy ... read more >
In two consolidated cases, San Diego County inmates brought suit in state court challenging overcrowding conditions at five detention facilities: the Las Colinas Detention Facility for Women, El Cajon, South Bay, Vista and Descanso detention facilities. Hudler v. Duffy was filed in 1977 and Armstrong v. Board of Supervisors was filed in 1987.

While we were unable to obtain the written opinion, the case is discussed in Wayne Welsh, Counties in Court: Jail Overcrowding and Court-Ordered Reform (1995). Welsh reports that the California Superior Court (Judge James L. Facht) issued a ruling in 1980, noting major problems with overcrowding and inadequate staffing in San Diego County and calling the jail an "architectural nightmare." Orders were made to improve staffing and reduce overcrowding. The case gave rise to a consent decree that imposed a cap on the population at the jail and gave the Superior Court jurisdiction to monitor the inmate population. Armstrong v. Bd. of Supervisors, No. 588349 (Super. Ct. San Diego County 1987), consolidated with Hudler v. Duffy, No. 404148 (Super. Ct. San Diego County 1977) (Judge Arthur W. Jones). The Superior Court of San Diego County retained jurisdiction to monitor and enforce the agreement.

Apparently in this or another ruling, on August 14, 1980, the Superior Court also held that the County's policy of strip searching all detainees was lawful. See Ward v. Cnty. of San Diego, 791 F.2d 1329 (9th Cir. 1986).

On August 29, 1994, the San Diego Superior Court found San Diego County officials in contempt of the consent degree by failing to provide adequate resources for the sheriff necessary to comply with the population cap in the decree, and imposed fines for willfully disobeying the terms of the consent decree. (A search did not find further information on this order.)

Members of the San Diego County Board of Supervisors sought a writ asking the Superior Court to vacate its order finding them in contempt of court. The Board alleged that the court exceeded its jurisdiction by interpreting the terms of the underlying consent decree and by usurping legislative discretion over the allocation of public funds.

On April 14, 1995, the California Court of Appeal (Judge Richard D. Huffman) vacated the contempt order as to the Board of Supervisors and directed that fines it paid be returned to to the Board. Bd. of Supervisors v. Superior Court, 33 Cal. App. 4th 1724 (1995). In particular, the appellate court found that there was not substantial evidence that the board willfully disobeyed the consent decree. Noting that the Board of Supervisors was charged with providing the sheriff with food, clothing and bedding for prisoners, it concluded that the Board had not been given direct authority over jail operations, such as the day-to-day compliance with the population cap.

A petition for rehearing was denied on May 5, 1995. We have no further information.

Denise Lieberman - 11/07/2005


compress summary

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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Pre-PLRA Population Cap
General
Sanitation / living conditions
Staff (number, training, qualifications, wages)
Type of Facility
Government-run
Causes of Action Habeas Corpus, 28 U.S.C. ยงยง 2241-2253; 2254; 2255
Defendant(s) San Diego County
Plaintiff Description Inmates of San Diego County complaining of crowded cells.
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Unknown
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1988 - n/a
Case Closing Year 1988
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)
No docket sheet currently in the collection
General Documents
Reported Opinion 04/14/1995 (33 Cal.App.4th 1724)
JC-CA-0016-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Huffman, Richard D. (State Trial Court, State Appellate Court)
JC-CA-0016-0001
Monitors/Masters None on record
Plaintiff's Lawyers Budd, Jordan C. (California)
JC-CA-0016-0001
Knoll, Gregory E. (California)
JC-CA-0016-0001
Landon, Alexander L. (California)
JC-CA-0016-0001
Levitan, Anson B. (New Mexico)
JC-CA-0016-0001
Scott, Charles (California)
JC-CA-0016-0001
Defendant's Lawyers Bardsley, Diane (California)
JC-CA-0016-0001
Harmon, Lloyd (California)
JC-CA-0016-0001
Northrup, Nathan (California)
JC-CA-0016-0001
Other Lawyers None on record

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