University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Guthrie v. Evans PC-GA-0006
Docket / Court 3068 ( S.D. Ga. )
State/Territory Georgia
Case Type(s) Prison Conditions
Case Summary
In September 1972, inmates of the Georgia State Prison (GSP) in Reidsville, Georgia, filed a class action lawsuit against GSP officials in the United States District Court for the Southern District of Georgia. The plaintiffs, represented by private counsel, filed an amended complaint in 1973, in ... read more >
In September 1972, inmates of the Georgia State Prison (GSP) in Reidsville, Georgia, filed a class action lawsuit against GSP officials in the United States District Court for the Southern District of Georgia. The plaintiffs, represented by private counsel, filed an amended complaint in 1973, in which they alleged that the prison racially segregated inmates and engaged in unconstitutional practices. Following a court order, GSP was desegregated in 1974.

The remaining issues raised in the complaint were tried before a Special Master in July 1976. Specifically, the Special Master heard complaints about (1) the adequacy of medical and psychiatric care, (2) substandard environmental conditions, (3) unconstitutional disciplinary practices, (4) guard brutality, (5) racial discrimination in work assignments and discipline, (6) verbal abuse, (7) infringements on the rights of Muslim inmates, (8) law library deficiencies, (9) the lack of education and vocational activities, and (10) interference with the mail.

In 1978, the parties negotiated and signed three consent decrees to resolve these issues. The consent decrees, signed July 19, August 4, and December 1, represented attempts to arrive at a comprehensive settlement agreement. The three consent decrees, however, failed to resolve problems with medical care, mental health services, and racially discriminatory discipline.

The United States District Court for the Southern District of Georgia appointed a Special Monitor to survey compliance with the consent decrees. On November 27, 1979, the Special Monitor reported widespread non-compliance with the consent decree. Specifically, the Special Monitor found that GSP was not giving inmates notice of charges against them, allowing them to call witnesses in a disciplinary hearing, and disciplining them too often with unmonitored bread and water diets that did not include vitamin supplements. In addition, the Special Monitor found problems with the plumbing and sewage systems and fire safety. The court granted the plaintiffs immediate relief on January 7, 1980. On February 11, 1980, the court permanently enjoined the defendants from using bread and water diets and again ordered the State to comply with the consent decrees and previous court orders.

In April of 1981, GSP implemented a new disciplinary system. The plaintiffs filed a motion alleging continuing violations of the court's previous orders, including the defendants' use of forfeiture of earned time as a disciplinary sanction. Following settlement talks, GSP agreed to expunge disciplinary convictions entered between August 4, 1978, and April 20, 1981, from inmates' records. In addition, forfeited earned time was credited to inmates and the disciplinary charge was either retried or dropped based on an inmate classification system (non-serious offenders, serious offenders who pled not guilty, or serious offenders who pled guilty). On December 31, 1980, the District Court (Chief Judge Anthony A. Alaimo) held the agreement was a full, fair and adequate settlement and overruled all objections to the settlement. Guthrie v. Evans, 93 F.R.D. 390 (S.D. Ga. 1981).

In 1985, an individual class member filed a pro se appeal in the Court of Appeals for the Eleventh Circuit. On April 24, 1987, the United States Court of Appeals for the Eleventh District (Chief Judge Paul H. Roney) held that an unnamed class member could not appeal the final judgment of the district court. Guthrie v. Evans, 815 F.2d 626 (11th Cir. 1987). The appellate court also held that an unnamed class member was not entitled to object to court orders, although such a person could contest a proposed consent decree.

Elizabeth Chilcoat - 06/01/2006


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Issues and Causes of Action
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Issues
Discrimination-basis
Race discrimination
General
Classification / placement
Disciplinary procedures
Disciplinary segregation
Education
Fire safety
Law library access
Mail
Religious programs / policies
Sanitation / living conditions
Type of Facility
Government-run
Causes of Action None on record
Defendant(s) Georgia State Prison
Plaintiff Description inmates of the Georgia State Prison in Reidsville, Georgia
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1972 - 1987
Case Closing Year 1987
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 ]

  Guthrie v. Evans: Civil Rights, Prison Reform, and Institutional Reform Litigation
By: Bradley S. Chilton (University of Georgia)
Citation: (1988) (unpublished Ph.D. dissertation, University of Georgia)
[ Detail ]

  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 ]

  Politics and Constitutional Interpretation in Prison Reform Litigation: The Case of Guthrie v. Evans
By: Bradley S. Chilton and Susette M. Talarico (Appalachian State University and University of Georgia)
Citation: in Courts, Corrections, and the Constitution: The Impact of Judicial Intervention on Prisons and Jails (John J. DiIulio, Jr. ed. 1990)
[ Detail ]

  Prisons Under the Gavel: The Federal Court Takeover of Georgia Prisons
By: Bradley S. Chilton (Appalachian State)
Citation: (1991)
[ Detail ]

Docket(s)
No docket sheet currently in the collection
General Documents
Order Approving Stipulation of the Parties 12/31/1981 (93 F.R.D. 390) (S.D. Ga.)
PC-GA-0006-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Reported Opinion 04/24/1987 (815 F.2d 626)
PC-GA-0006-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Alaimo, Anthony A. (S.D. Ga.)
PC-GA-0006-0002
Hill, Harold N. Jr. Court not on record
PC-GA-0006-0001
Kravitch, Phyllis A. (Eleventh Circuit, Fifth Circuit)
PC-GA-0006-0001
Roney, Paul Hitch (Fifth Circuit, FISCR, Eleventh Circuit)
PC-GA-0006-0001
Monitors/Masters None on record
Plaintiff's Lawyers Bishop, Sanford D. Jr. (Georgia)
PC-GA-0006-0002
Cullen, Robert W. (Georgia)
PC-GA-0006-0002
Ralston, Charles Stephen (New York)
PC-GA-0006-0002
Winter, Steven L. (New York)
PC-GA-0006-0002
Defendant's Lawyers Childers, Neal B. (Georgia)
PC-GA-0006-0001
Davis, G. Thomas (Georgia)
PC-GA-0006-0002
Dumich, Nicholas G. (Georgia)
PC-GA-0006-0002
Kohler, Harrison (Georgia)
PC-GA-0006-0002
Walden, John C. (Georgia)
PC-GA-0006-0002
Other Lawyers Days, Drew S. III (District of Columbia)
PC-GA-0006-0002
Lawrence, Paul S. (District of Columbia)
PC-GA-0006-0002

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