University of Michigan Law School
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Case Name Woods v. Edwards PC-LA-0010
Docket / Court 93-744 ( M.D. La. )
State/Territory Louisiana
Case Type(s) Prison Conditions
Case Summary
On August 26, 1993, Claude Woods, an inmate in the Louisiana State Penitentiary at Angola, filed suit as a pro se plaintiff under 42 U.S.C. § 1983 alleging that his status at the prison in "extended lockdown," a form of disciplinary isolation, was motivated by racial animus or was in retaliation ... read more >
On August 26, 1993, Claude Woods, an inmate in the Louisiana State Penitentiary at Angola, filed suit as a pro se plaintiff under 42 U.S.C. § 1983 alleging that his status at the prison in "extended lockdown," a form of disciplinary isolation, was motivated by racial animus or was in retaliation for filing lawsuits. Woods also contended that his continued confinement was wrongful, that some conditions of his confinement were unconstitutional, and that his due process rights were violated. A prison disciplinary board had determined that Woods had written threatening letters to individuals outside the prison and forged the name of another prisoner as the author. On July 23, 1991, he was placed in extended lockdown for these infractions. Woods's status was reviewed every 90 days in accordance with prison guidelines, and the board continued his confinement in extended lockdown citing the serious nature of his offenses. The U.S. District Court for the Middle District of Louisiana (Chief Judge John V. Parker) granted defendants' motion for summary judgment and Woods appealed. The Fifth Circuit Court of Appeals affirmed the District Court's grant of summary judgment on June 5, 1995. Woods v. Edwards, 51 F.3d 577 (5th Cir. 1995). The court held that the extended lockdown of Woods, a racial minority, for nearly four years while similarly situated white prisoners were released, did not violate his equal protection rights because Woods failed to present evidence of discriminatory intent on the part of the prison officials. The court further found that confinement to an uncomfortably hot cell could not alone support a finding that Woods was subjected to ""cruel and unusual punishment"" in violation of the Eighth Amendment; and Woods had received all of the process to which he was entitled.

The court did note that Woods had been in extended lockdown for almost four years. Therefore, the review board and the magistrate assigned to the case (Magistrate Judge Stephen C. Riedlinger) were instructed to consider the need for continuing to keep Woods in that status.

Tom Madison - 01/16/2006


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Issues and Causes of Action
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Issues
Discrimination-basis
Race discrimination
General
Administrative segregation
Classification / placement
Disciplinary procedures
Disciplinary segregation
Sanitation / living conditions
Totality of conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Louisiana State Penitentiary
Plaintiff Description Inmate who had been confined in extended lockdown challenging this discipline as violative of his equal protection rights
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief Litigation
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
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)
3:93-CV-00744-jvp-scr (M.D. La.) 06/05/1995
PC-LA-0010-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Reported Opinion 05/10/1995 (51 F.3d 577)
PC-LA-0010-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Garwood, William Lockhart (Fifth Circuit)
PC-LA-0010-0001
King, Carolyn Dineen (Fifth Circuit)
PC-LA-0010-0001
Parker, James Aubrey (D.N.M.)
PC-LA-0010-9000
Riedlinger, Stephen C. (M.D. La.) [Magistrate]
PC-LA-0010-9000
Wisdom, John Minor (Fifth Circuit)
PC-LA-0010-0001
Monitors/Masters None on record
Plaintiff's Lawyers None on record
Defendant's Lawyers Sanders, David Glen (Louisiana)
PC-LA-0010-0001 | PC-LA-0010-9000
Other Lawyers None on record

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