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Case Name Lareau v. Manson PC-CT-0013
Docket / Court 78-145 ( D. Conn. )
State/Territory Connecticut
Case Type(s) Prison Conditions
Case Summary
In 1980 inmates of the Hartford Community Correctional Center ("HCCC") filed separate lawsuits under 42 U.S.C. § 1983 in the United States District Court for the District of Connecticut against the Warden of the prison and the Commissioner of Corrections for overcrowding, inadequacies in ... read more >
In 1980 inmates of the Hartford Community Correctional Center ("HCCC") filed separate lawsuits under 42 U.S.C. § 1983 in the United States District Court for the District of Connecticut against the Warden of the prison and the Commissioner of Corrections for overcrowding, inadequacies in health care, sanitation, food, heating, recreation, counseling services and safety. Plaintiffs were represented by various legal services organizations in Connecticut. The plaintiffs' actions were consolidated into one class action. The Court (Judge Jose A. Cabranes) found for the plaintiffs on the issue of overcrowding but in doing so, it held that the overcrowding was the root of most of the other complaints and refused to find additional specific violations. The Court ordered specific remedies to deal with the overcrowding and the ancillary issues related to it, and defendants appealed. Lareau v. Manson, 507 F.Supp. 1177 (D.CT. 1980).

On June 1, 1981, the United States Court of Appeals for the Second Circuit affirmed the Court's decision in the following ways: (1) the prison violated due process rights of pretrial detainees by confining them and other inmates in overcrowded conditions not reasonably related to a legitimate goal to justify forcing them to endure genuine privation and hardship over an extended period of time; and (2) subjecting sentenced inmates to combination of double-bunking and overcrowded dayrooms violated their Eighth Amendment rights when imposed for a period of time in excess of 30 days. The Appellate Court modified and remanded the Court's holding on a strict design capacity population cap and an absolute prohibition of any double bunking. The Court found these provisions unfeasible. It instructed that the more flexible and feasible alternative was to limit the maximum duration of the inmates' confinement in the double cells rather than prohibit double bunking altogether and it remanded the provision back for appropriate modification. Lareau v. Manson, 651 F.2d 96 (2nd Cir. 1981).

No further information is available.

Rebecca Bloch - 04/21/2006


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
Pre-PLRA Population Cap
General
Counseling
Food service / nutrition / hydration
Recreation / Exercise
Sanitation / living conditions
Staff (number, training, qualifications, wages)
Totality of conditions
Medical/Mental Health
Medical care, general
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Hartford Community Correctional Center
Plaintiff Description inmates of the Hartford Community Correctional Center
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1980 - n/a
Case Closing Year n/a
Case Ongoing Unknown
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)
No docket sheet currently in the collection
General Documents
Memorandum of Decision 12/29/1980 (507 F.Supp. 1177) (D. Conn.)
PC-CT-0013-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Reported Opinion 06/01/1981 (651 F.2d 96)
PC-CT-0013-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Cabranes, Jose Alberto (Second Circuit, D. Conn., FISCR)
PC-CT-0013-0001
Friendly, Henry Jacob (Second Circuit)
PC-CT-0013-0002
Kearse, Amalya Lyle (Second Circuit)
PC-CT-0013-0002
Mansfield, Walter Roe (S.D.N.Y., Second Circuit)
PC-CT-0013-0002
Monitors/Masters None on record
Plaintiff's Lawyers Blue, Jon C. (Connecticut)
PC-CT-0013-0001 | PC-CT-0013-0002
Greene, James W. Jr. (Connecticut)
PC-CT-0013-0001 | PC-CT-0013-0002
Stone, Martha (Connecticut)
PC-CT-0013-0001 | PC-CT-0013-0002
Defendant's Lawyers Ajello, Carl R. (Connecticut)
PC-CT-0013-0001 | PC-CT-0013-0002
Bezanson, Lee (Connecticut)
PC-CT-0013-0001
O'Neill, Stephen J. (Connecticut)
PC-CT-0013-0001 | PC-CT-0013-0002
Other Lawyers None on record

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