Filed Date: April 25, 1986
Closed Date: 1990
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On April 25, 1986, a jail inmate filed a pro se lawsuit in the U.S. District Court for the Eastern District of Tennessee under 42 USC §1983 against Knox County and Tennessee officials regarding conditions at the Knox County Jail. A magistrate judge grated the inmate counsel and the case was eventually certified as a class action. Plaintiffs were represented by the University of Tennessee Legal Clinic. On January 25, 1989, the district court (Judge James H. Jarvis) found serious overcrowding at two of the three Knox County facilities. Carver v. Knox County, 753 F.Supp 1370 (E.D. Tenn. 1989). The court held that this overcrowding led to unconstitutional conditions and ordered the county and state to reduce the prison populations. The state defendants filed a motion for change of venue to consolidate this action with Grubbs v. Reynolds, a class action lawsuit concerning conditions within the state prison system, that was under the jurisdiction of the U.S. District Court for the Middle District of Tennessee. The motion was denied.
Judge Jarvis issued another opinion regarding the overcrowded conditions on March 17, 1989, after hearing further evidence from the parties. Carver v. Knox County, 753 F.Supp. 1394 (E.D. Tenn 1989). The court ordered the removal of more state prisoners from the jail. Judge Jarvis noted that the overcrowded conditions were a result of the 1985 order by Judge Thomas A. Higgins in the Grubbs litigation in the Middle District of Tennessee, which limited the number of inmates who could be accommodated within the Tennessee State Prison System, slowing down the movement of inmates from county to state facilities.
On appeal, the Sixth Circuit Court of Appeals (Judge Pierce Lively) noted that there were conflicting goals between this Carver case and the Grubbs litigation. Carver v. Knox County, 887 F.2d 1287 (6th Cir. 1989). The Sixth Circuit ordered the district court to sever the claims against the state defendants and transfer them to the Middle District of Tennessee. It also found that the district court's conclusion that all of the unconstitutional conditions at the Knox County facilities were a result of inmates from the state system was not supported by the evidence. The claims against the county defendants were remanded to the district court. The U.S. Supreme Court denied certiorari on April 30, 1990. Knox County v. McWherter, 495 U.S. 919 (1990)
On remand, Judge Jarvis adopted his previous opinions except as they discussed the cause of the unconstitutional conditions. Carver v. Knox County, 753 F.Supp. 1398 (E.D. Tenn. 1990). Judge Jarvis wrote that "the court concludes that it has already accomplished precisely what the Sixth Circuit now orders on remand."
Summary Authors
Kristen Sagar (6/13/2007)
Richard Jolly (11/4/2014)
Grubbs v. Bradley, Middle District of Tennessee (1980)
Eldridge, John E. (Tennessee)
Beeler, Richard T. (Tennessee)
Burson, Charles W. (Tennessee)
Duffey, John (Tennessee)
Himmelreich, Davis (Tennessee)
Jarvis, James Howard II (Tennessee)
Lively, Pierce (Kentucky)
Last updated Feb. 15, 2024, 3:28 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: Tennessee
Case Type(s):
Key Dates
Filing Date: April 25, 1986
Closing Date: 1990
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
inmates of the Knox County Jail
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: Yes
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Source of Relief:
Order Duration: 1989 - 0
Issues
General:
Food service / nutrition / hydration
Jails, Prisons, Detention Centers, and Other Institutions:
Medical/Mental Health:
Type of Facility: