On October 26, 1990, prisoners at the Pelican Bay State Prison in Crescent City, California filed a class action lawsuit under 42 U.S.C. § 1983 against the California Department of Corrections in the U.S. District Court for the Northern District of California. The plaintiffs, represented by the Prison Law Office, alleged that the conditions of their confinement were unconstitutional, and they asked the court for declaratory and injunctive relief. Specifically, the plaintiffs alleged that the defendants unconstitutionally condoned a pattern and practice of using excessive force against inmates, failed to provide inmates with adequate medical care, failed to provide inmates with adequate mental health care, imposed inhumane conditions in the Security Housing Unit, utilized cell-assignment procedures that exposed inmates to an unreasonable risk of assault from other inmates, failed to provide adequate procedural safeguards when segregating the prison gang affiliates in the Security Housing Unit, and failed to provide inmates with adequate access to the courts.
On January 10, 1995, the U.S. District Court for the Northern District of California (Judge Thelton E. Henderson) granted injunctive relief to the plaintiffs, holding that: 1) there was unnecessary and wanton infliction of pain and use of excessive force at the prison; 2) prison officials did not provide inmates with constitutionally adequate medical and mental health care; 3) conditions of confinement in the Security Housing Unit, which included extreme isolation and environmental deprivation, did not inflict cruel and unusual punishment on all inmates, but conditions in the Security Housing Unit did impose cruel and unusual punishment on mentally ill prisoners; 4) some procedures used to validate inmates as gang members and thus transfer them to the Security Housing Unit violated due process. The court then appointed Thomas F. Lonergan to serve as Special Master for the case, and ordered the defendants to pay him $125 per hour. The court ordered the parties to work with the Special Master in good faith to develop a remedial plan addressing the constitutional violations and to submit the plan to the court within 120 days. Madrid v. Gomez, 889 F.Supp. 1146 (N.D.Cal. 1995). The defendants appealed.
The defendants also asked the district court to modify its order that they must pay the hourly rate of the special master. They argued that the Prison Litigation Reform Act (PLRA) applied retrospectively to this case, and that the PLRA required the court to reset the special master's rate and the judiciary to bear the expense of paying him. On August 23, 1996, the U.S. District Court for the Northern District of California (Judge Henderson) denied the request, holding that the PLRA did not apply retroactively to this case because this case did not provide for prospective relief. Madrid v. Gomez, 940 F.Supp. 247 (N.D.Cal. 1996). The defendants appealed this ruling.
On December 24, 1996, the U.S. Court of Appeals for the Ninth Circuit (Judge Betty Binns Fletcher, Judge Joseph Jerome Farris, and Judge Atsushi Wallace Tashima) denied the appeal, holding that the district court's determinations were not clearly erroneous. Wilson v. U.S. Dist. Court for the Eastern Dist. of California, 103 F.3d 828 (9th Cir. 1996). The defendants appealed. On May 19, 1997, the U.S. Supreme Court declined to hear the appeal. Wilson v. U.S. Dist. Court for the Eastern Dist. of California, 520 U.S. 1230 (1997).
On September 21, 1995, the parties stipulated to, and the district court (Judge Henderson) authorized, an "informal process" of expediting the payments of attorneys' fees. Pursuant to the stipulation, the defendants were to pay fees at the current market rate for all legal services that were useful and necessary to ensure compliance. If the defendants ever disputed an amount and refused to pay, the plaintiffs could seek an order from the district court to resolve the dispute. On April 26, 1996, Congress passed the PLRA, which limited the amount of attorneys' fees that can be awarded to prisoners' counsel by capping the maximum hourly rate and prohibiting payment of fees that are not directly and reasonably incurred in proving a violation of prisoners' rights.
On October 28, 1996, the district court (Judge Henderson) made an award of attorneys' fees for legal services performed prior to the enactment of the PLRA, and on June 13, 1997, the district court ordered payment of fees for services performed subsequent to the enactment of the PLRA. In neither case did the district court invoke the PLRA's limitations, reasoning that applying the attorneys' fee limitations to a case which was pending at the time of the statute's enactment would produce a retroactive effect, violating basic notions of fair notice, reasonable reliance, and settled expectations. The defendants appealed.
On July 2, 1998, the U.S. Court of Appeals for the Ninth Circuit (Judge Harlington Wood, Jr., Judge Cynthia Holcomb Hall, and Judge Diarmuid Fionntain O'Scannlain) reversed the district court's decision with respect to post-enactment fee awards, holding: 1) that the PLRA's attorney-fee provisions apply to all post-enactment awards, regardless of when the case was filed and regardless of when the legal services were provided; 2) that given the attorneys' unsettled expectations when they took the case, the PLRA would not have an improper retroactive effect if applied here; 3) that strict scrutiny did not apply to the prisoners' claim that the PLRA violated their equal protection rights; and 4) that the PLRA's attorney-fee provisions did not violate the equal protection component of the Fifth Amendment. Madrid v. Gomez, 150 F.3d 1030 (9th Cir. 1998).
On August 30, 1999, the U.S. Court of Appeals for the Ninth Circuit (Judge Wood, Judge Hall, and Judge O'Scannlain) superseded their July 2, 1998 decision, partially affirming and partially reversing the previous ruling. The court held: 1) that the fee limitations of the PLRA did not apply to awards that were entered after the PLRA's enactment but covered services performed prior to enactment; 2) that the PLRA's attorney fee limitations still applied to fee awards entered after the PLRA's effective date, covering fees incurred after that date; 3) that strict scrutiny did not apply to the prisoners' claim that the PLRA violated their equal protection rights; and 4) that the PLRA satisfied the equal protection component of the Fifth Amendment. Madrid v. Gomez, 190 F.3d 990 (9th Cir. 1999).
On November 17, 2004, after a lengthy investigation and report by the new Special Master John Hagar, the district court (Judge Henderson) found a series of systematic problems in the California Department of Corrections' compliance monitoring in the case the Pelican Bay. The court noted that the defendants' system for investigating and disciplining officers was "broken to the core," and that the defendants had deliberately misled the court by filing false reports. The court gave defendant Thomas Moore two weeks to show cause why he should not be sanctioned for misleading the court through false reports. The court then ordered the defendants to work with the Special Master to develop a remedial plan to address the problems with the investigations. The court also partially granted the motion of the California Correctional Peace Officer's Association (CCPOA) to intervene, ordering them to show cause why they should not be sanctioned for misleading the court. Madrid v. Woodford, C90-3094, 2004 WL 2623924 (N.D.Cal. Nov. 17, 2004).
On March 16, 2005, the district court (Judge Henderson) sanctioned defendant Moore in the amount of $1,500.00, payable within two weeks. The court declined to sanction the CCPOA. On January 13, 2006, the district court ordered the defendants to fund and fill the following full time positions at the prison: one additional registered nurse, one additional psychiatrist or psychologist, one additional associate government program analyst, three additional office technicians, three additional medical records technicians, and two additional primary care providers.
As of October 3, 2008, the last entry on the docket is listed on September 15, 2008. The case appears to be ongoing, with docket updates following about two weeks behind the court's orders.Kristen Sagar - 10/03/2008