University of Michigan Law School
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Case Name Inmates of Indiana State Farm v. Bayh PC-IN-0004
Docket / Court 82-0477 ( S.D. Ind. )
State/Territory Indiana
Case Type(s) Prison Conditions
Case Summary
In 1982, inmates at the Indiana State Farm sued the state of Indiana because of overcrowding and a lack of sufficient staffing, including medical staffing. It is not clear who was representing the inmates at that time, if anyone, but at some point in the litigation, the ACLU provided ... read more >
In 1982, inmates at the Indiana State Farm sued the state of Indiana because of overcrowding and a lack of sufficient staffing, including medical staffing. It is not clear who was representing the inmates at that time, if anyone, but at some point in the litigation, the ACLU provided representation. Four years after filing the complaint, on February 18, 1986, the district court for the Southern District of Indiana approved a consent decree between the parties and ordered renovation of the facility, and increase in staffing, and minimum levels of medical staffing - including employment of one full-time and one part-time doctor on site. In subsequent years, this original decree was amended on several occasions and the litigation continued.

On October 19, 1988, the court modified its original order to allow the state to construct new buildings at the prison instead of renovating the existing ones and to reduce the minimum number of hours a psychiatrist was required to be on site. After some further litigation, on October 13, 1995, the court approved a joint report indicating that the new facilities had been completed and the shortage of medical staff had been remedied. The population was set at 1,650 and that limit was not yet met at that time.

In September 1996, the inmates again alleged that the state was not in compliance with the requirement to staff one full-time and one part-time physician at the prison and moved for an order for the state to show cause why it should not be held in contempt for violating the decree. The court entered a show cause order on September 25, 1996 and scheduled a hearing for November 14, 1996. Before the hearing, on October 15, 1996, the state moved, under the Prison Litigation Reform Act (PLRA), to terminate all previously granted prospective relief. The PLRA, which applied to prospective relief granted before or after its enactment, provided that such relief could be granted only if specific findings were entered that the remedy was narrowly drawn, necessary to correct a the violation of a federal right, and the least intrusive means of correcting that violation were made. On November 12, 1996, two days before the scheduled hearing, the inmates moved to enjoin the stay provision. On November 14, 1996, they filed a response to the states' termination request in which they argued that the PLRA was unconstitutional.

On that same day, the court held the show cause hearing on the contempt claim, and also heard some argument on the preliminary injunction. The U.S. District Court for the Southern District of Indiana (Judge Larry J. McKinney) determined that the inmates had demonstrated that the state was not in compliance with the modified consent decree with regard to medical staffing as the state only had two doctors on contract. Inmates at the Indiana State Farm, v. Bayh, No. 82-0477 (S.D. Ind. Nov. 20, 1996) (order declaring state's contempt and requesting additional briefing). The state argued that the staffing levels were sufficient to satisfy the spirit of the decree, but the court held that the state should have sought to modify the decree if that were the case. Accordingly, the court found the state in contempt. The court issued an automatic stay.

Despite the finding that the state was in contempt, the court felt that it could not order compliance with the decree in light of the PLRA. With respect to the state's termination request under the PLRA, the court first determined that it should not address the inmates' constitutional challenge until trying to resolve the matter on non-constitutional grounds. The court reasoned that it could do this in one of two ways. The first option was to examine the record to see if evidence existed to support the specific findings required by the act. However, that option was deemed impossible as no findings were ever made during the course of the litigation nor was any evidence presented at the hearing that day that would satisfy the PLRA's requirements. The court then ordered the parties to do one of three things within thirty days: either present evidence at a hearing that would satisfy the PLRA's findings requirements; request a hearing to present evidence and defend a modification of the original decree; or simply provide the court with evidence upon which it could reach a determination regarding the findings requirement. Otherwise, the court would proceed on the constitutional challenge.

On April 17, 1997, the Court appointed Dr. Ronald Shansky as the Court's expert in the case. Following that appointment, plaintiffs challenged the constitutionality of the PLRA by filing a motion for partial summary judgment on October 2, 1997. After that motion was fully briefed by the parties, on August 31, 1998, the District Court denied the motion and held that § 3626(b)(2) of the PLRA was constitutional. The matter was then set for an evidentiary hearing.

The Court reset the hearing date several times at the request of the parties so that settlement discussions could be pursued. On July 12, 2000, the District Court granted the defendants' motion to terminate prospective relief and terminated the Consent Decree and all subsequent orders as to the Putnamville Correctional Facility. The case was then closed.

Sherrie Waldrup - 03/06/2006

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Issues and Causes of Action
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Content of Injunction
Preliminary relief granted
Crowding / caseload
Staff (number, training, qualifications, wages)
Type of Facility
Causes of Action 42 U.S.C. § 1983
Defendant(s) Indiana State Farm
State of Indiana
Plaintiff Description All inmates confined, or in the future that will be confined, at the Indiana State Farm.
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 Preliminary injunction / Temp. restraining order
Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1986 - 2000
Case Closing Year 2000
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 ]

IP82-C-0477 -M/S (S.D. Ind.) 11/15/2000
PC-IN-0004-9000 PDF | Detail
General Documents
Order 11/20/1996 (S.D. Ind.)
PC-IN-0004-0001 PDF | Detail
Judgment 07/12/2000 (S.D. Ind.)
PC-IN-0004-0002 PDF | Detail
Judges McKinney, Larry J. (S.D. Ind.)
PC-IN-0004-0001 | PC-IN-0004-0002
Monitors/Masters None on record
Plaintiff's Lawyers Falk, Kenneth J. (Indiana)
PC-IN-0004-0001 | PC-IN-0004-9000
Kashani, Hamid R. (Indiana)
Defendant's Lawyers Arthur, David A. (Indiana)
PC-IN-0004-0001 | PC-IN-0004-9000
Other Lawyers None on record

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