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Case Name Anderson v. Redman PC-DE-0006
Docket / Court 76-364 ( D. Del. )
State/Territory Delaware
Case Type(s) Prison Conditions
Case Summary
In 1976, inmates at the Delaware Correctional Center, represented by counsel from the community Legal Aid Society, filed a section 1983 class action suit in the U.S. District Court for the District of Delaware against prison officials. The original complaint, docket 76-202, was superseded by an ... read more >
In 1976, inmates at the Delaware Correctional Center, represented by counsel from the community Legal Aid Society, filed a section 1983 class action suit in the U.S. District Court for the District of Delaware against prison officials. The original complaint, docket 76-202, was superseded by an identical complaint filed later that year with the docket 76-364. (The multiple filings were a result of the uncertainty regarding the status of the three-judge court act, 28 USC section 2281. After the act was repealed by Congress all parties agreed to the filing of the new complaint.) Plaintiffs alleged unconstitutional overcrowding as well as violation of various state laws regarding housing of inmates, and sought injunctive relief. After a seven day trial, Judge Murray Schwartz granted plaintiffs' motion for immediate relief from overcrowding in the receiving section of the facility, holding conditions there to be in violation of the Eighth Amendment. But his opinion dated February 16, 1977, Judge Schwartz declined to rule more permanently on the federal constitutional issue and instead found that the general overcrowding of the facility was in violation of state statutory laws. The court ordered the defendants to remedy the problem by reducing inmate population, and set out eight pages of what it termed ""suggestions"" rather than ""mandatory requirements."" Anderson v. Redman, 428 F. Supp. 1105, 1128 (D. Del. 1977). Plaintiffs sought and were awarded attorneys' fees. 474 F. Supp. 511, 524 (D. Del. 1979).

In June 1979, the Delaware legislature passed a law specifically written to undercut the state law premise of the 1977 order. Defendants sought to vacate the earlier order while plaintiffs wanted the new state law declared unconstitutional under the Delaware state constitution. Judge Schwartz abstained from entertaining the state constitutional challenge and stayed his 1977 order until the constitutionality of the state law could be determined in the Delaware state courts. Anderson v. Redman, 480 F. Supp. 830, 833 (D. Del. 1979). There is no further information on the outcome of this case.

In 1984, The U.S. Supreme Court held that federal courts lack jurisdiction to enjoin compliance with state statutes. Pennhurst State School v. Halderman, 465 U.S. 89 (1984).

John Maksymonko - 07/26/2005


compress summary

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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
General
Sanitation / living conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
42 U.S.C. ยง 1983
Defendant(s) Delaware
Plaintiff Description Convicted state inmates and pretrial detainees held at the Delaware Correctional Center challenging the overcrowded living conditions
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Unknown
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 1977 - n/a
Case Closing Year 1979
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)
No docket sheet currently in the collection
General Documents
Opinon 02/16/1977 (429 F.Supp. 1105) (D. Del.)
PC-DE-0006-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 06/18/1979 (474 F.Supp. 511) (D. Del.)
PC-DE-0006-0003 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 11/28/1979 (480 F.Supp. 830) (D. Del.)
PC-DE-0006-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Schwartz, Murray Merle (D. Del.)
PC-DE-0006-0001 | PC-DE-0006-0002 | PC-DE-0006-0003
Monitors/Masters None on record
Plaintiff's Lawyers Myers, Gary A. (Delaware)
PC-DE-0006-0001 | PC-DE-0006-0002 | PC-DE-0006-0003
Schab, H. William Jr. (Delaware)
PC-DE-0006-0001 | PC-DE-0006-0002 | PC-DE-0006-0003
Defendant's Lawyers Barron, Norman A. (Delaware)
PC-DE-0006-0002
Halberstadt, Bertram S. (Delaware)
PC-DE-0006-0001
Parkins, John A. Jr. (Delaware)
PC-DE-0006-0001 | PC-DE-0006-0002 | PC-DE-0006-0003
Polk, John J. (Delaware)
PC-DE-0006-0001 | PC-DE-0006-0003
Trostle, Keith A. (Delaware)
PC-DE-0006-0002
Other Lawyers None on record

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