University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Crowe v. Jones PC-AL-0014
Docket / Court 96-214 ( S.D. Ala. )
State/Territory Alabama
Case Type(s) Prison Conditions
Case Summary
On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were ... read more >
On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were in violation of a consent decree issued in an earlier case, Pugh v. Locke, 406 F. Supp. 318 (M.D. Ala. 1976) (PC-AL-010), which mandated that there "shall be space available for inmates to engage in hobbies." Pugh, 406 F. Supp. at 335. The inmates were granted leave to proceed in forma pauperis, and each inmate represented himself pro se.

The inmates alleged that the "spirit and intent of the consent decree" was being violated in several ways by defendants. For example, the inmates alleged that defendants limited the amount of supplies inmates could order each month, limited the amount of finished crafts that inmates could mail out of the facility and to whom inmates could mail such crafts, limited the number of inmates who were allowed access to the hobby shop in a selective and discriminatory manner, and often closed the shop for up to two weeks as group punishment for incidents unrelated to the hobby shop. Restricted access to the hobby shop, according to the inmates, was a violation of the Eight Amendment because it restricted the inmates' means to make an income, and because the hobby shop was essential in order to maintain a safe environment in the overcrowded prison.

The U.S. District Court for the Southern District of Alabama found that the inmates had not made a successful claim, because they could not show that they had been deprived of a constitutional right. Specifically, the court found that: 1) there existed no constitutionally protected right for an inmate to have access to a hobby shop; 2) the claim that the denied access was in violation of the Pugh consent decree was not a violation of a federal right because the consent decree was no longer in effect following Newman v. Alabama, No. 3501-N, 1988 U.S. Dist. LEXIS 18633, (M.D. Ala. Dec. 28, 1998)(PC-AL-017) and because access to a hobby shop was not a constitutionally protected liberty interest and 3) denied or restricted access to a hobby shop is not a deprivation of a single human need, and therefore is not an Eight Amendment violation. The case was dismissed without prejudice as frivolous, prior to service of process (Judge Richard W. Vollmer, Jr. signed the Report and Recommendations issued by Mag. Judge William H. Steele on May 13, 1996). Crowe v. Jones, 96-0214, 1996 U.S. Dist. LEXIS 8566 (S.D. Ala. May 13, 1996).

Megan Raynor - 01/23/2006


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Issues and Causes of Action
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Issues
General
Recreation / Exercise
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. ยง 1983
Defendant(s) Alabama Department of Corrections
Plaintiff Description Alabama prison inmates whose claims concern the restrictions placed on their access and use of the hobby shop at Holman Correctional Facility
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1996
Case Ongoing No
Additional Resources
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Case Studies Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
By: Margo Schlanger (Washington University)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
96-214 (S.D. Ala.) 06/04/1996
PC-AL-0014-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Order 05/13/1996 (1996 U.S.Dist.LEXIS 8566) (S.D. Ala.)
PC-AL-0014-0002.pdf | LEXIS | Detail
Document Source: LexisNexis
Judges Steele, William H. (S.D. Ala.) [Magistrate]
PC-AL-0014-0002 | PC-AL-0014-9000
Vollmer, Richard W. Jr. (S.D. Ala.)
PC-AL-0014-9000
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers None on record
Other Lawyers None on record

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