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Case Name Patchette v. Nix PC-IA-0011
Docket / Court 90-80230 ( S.D. Iowa )
State/Territory Iowa
Case Type(s) Prison Conditions
Case Summary
On October 11, 1989, prisoners from the Iowa State Penitentiary in Fort Madison, Iowa filed a lawsuit under 42 U.S.C. 1983 against the Iowa State Penitentiary's Warden and the Director of the Iowa Department of Corrections in the United States District Court for the Southern District of Iowa. The ... read more >
On October 11, 1989, prisoners from the Iowa State Penitentiary in Fort Madison, Iowa filed a lawsuit under 42 U.S.C. 1983 against the Iowa State Penitentiary's Warden and the Director of the Iowa Department of Corrections in the United States District Court for the Southern District of Iowa. The plaintiffs, represented by court-appointed counsel, alleged that prison overcrowding produced conditions that made incarceration cruel and unusual punishment and that new visitation policies and practices violated the inmates' liberty interest in visitation.

The United States District Court for the Southern District of Iowa (Judge Charles R. Wolle) refused the plaintiff's request for a Temporary Restraining Order on October 11, 1989. On April 24, 1990, the court held that the change in visitation hours violated due process by limiting rather than applying inmates' rights, but declined to conclude that overcrowded conditions violated the Eighth Amendment. Both parties appealed.

On November 29, 1991, the United States Court of Appeals for the Eighth Circuit (Judge Howard F. Sachs) affirmed the lower court's ruling. Pachette v. Nix, 952 F.2d 158 (8th Cir. 1991). The Eighth Circuit held that the Iowa Administrative Code 21.5(1) created a liberty interest in visitation by mandating specific visiting hours, which the prison violated by reducing visitation hours to cope with volitional overcrowding. In addition, the court found that there was insufficient evidence to show that overcrowding endangered prison security or led to inadequate food, medical care, and sanitation. The court noted that a 50% shortage of toilets might be considered cruel and unusual punishment if corrective action was not already planned.

We do not have the pleadings or any information on subsequent proceedings.

Elizabeth Chilcoat - 06/01/2006


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Issues and Causes of Action
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Issues
General
Food service / nutrition / hydration
Sanitation / living conditions
Visiting
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. ยง 1983
Defendant(s) Iowa Department of Corrections
Iowa State Penitentiary
Plaintiff Description Prisoners contending that they had liberty interest in existing visitation regulations and that changing those regulations and overcrowding prison conditions violated their constitutional rights
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted Unknown
Prevailing Party Mixed
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1990 - n/a
Case Closing Year 1991
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)
89-80656 (S.D. Iowa) 04/27/1992
PC-IA-0011-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
4:89-cv-80656-CRW (S.D. Iowa) 06/01/1993
PC-IA-0011-9001 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Reported Opinion 11/29/1991 (952 F.2d 158)
PC-IA-0011-0001 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Bowman, Pasco Middleton II (Eighth Circuit)
PC-IA-0011-0001
Gibson, John R. (Eighth Circuit, W.D. Mo.)
PC-IA-0011-0001
Sachs, Howard Frederic (W.D. Mo.)
PC-IA-0011-0001
Wolle, Charles Robert (S.D. Iowa)
PC-IA-0011-9000 | PC-IA-0011-9001
Monitors/Masters None on record
Plaintiff's Lawyers Mears, Philip B. (Iowa)
PC-IA-0011-0001 | PC-IA-0011-9001
Defendant's Lawyers Achen, Susan M. (Iowa)
PC-IA-0011-9001
Allen, Gordon E. (Iowa)
PC-IA-0011-0001
Hill, William A. (Iowa)
PC-IA-0011-0001
Lindebak, Layne M. (Iowa)
PC-IA-0011-0001 | PC-IA-0011-9000
Other Lawyers None on record

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