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Case Name Chapman v. Rhodes PC-OH-0003
Docket / Court C-1-75-251 ( S.D. Ohio )
State/Territory Ohio
Case Type(s) Prison Conditions
Case Summary
In 1975, two inmates at the Southern Ohio Correctional Facility filed a lawsuit, pro se, under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Ohio against officials of the Ohio State Prison system. Certification as a class action was originally denied on the ground that ... read more >
In 1975, two inmates at the Southern Ohio Correctional Facility filed a lawsuit, pro se, under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Ohio against officials of the Ohio State Prison system. Certification as a class action was originally denied on the ground that the asserted representatives were not qualified to represent the claimed class. After the American Civil Liberties Union entered appearances on behalf of the plaintiffs, the case was certified as a class action. Plaintiffs alleged that defendants' practice of double celling, whereby two inmates were housed in a single cell, constituted cruel and unusual punishment in violation of the Eighth Amendment.

On June 29, 1977, the District Court (Chief Judge Timothy Sylvester Hogan) held that although housing two inmates in one cell was not unconstitutional per se, the limited amount of square-footage provided to prisoners at Southern Ohio Correctional Facility rendered double-celling under the circumstances unconstitutional. Chapman v. Rhodes, 434 F. Supp. 1007 (S.D. Ohio 1977). Judge Hogan ordered defendants to produce a plan within 90 days that would terminate double celling at Southern Ohio Correctional Facility. Defendants appealed and on June 6, 1980, the Sixth Circuit affirmed without opinion. Chapman v. Rhodes, 624 F.2d 1099 (6th Cir. 1980). The Supreme Court granted certiorari and the plaintiffs' motions to proceed in forma pauperis. Rhodes v. Chapman, 449 U.S. 951 (1980).

The Supreme Court (Justice Lewis Franklin Powell) reversed. Rhodes v. Chapman, 452 U.S. 337 (1981). Writing for the majority, Justice Powell held that double celling at the prison did not violate the Eighth Amendment, noting that despite the fact that prisoners were serving long sentences, that double-celling wasn't temporary, that the prison was over capacity, and that prisoners spent much time in the cells with their cellmates, the conditions of double-celling were nevertheless insufficient to constitute cruel and unusual punishment. Justices Brennan and Blackmun filed concurring opinions, and Justice Marshall filed a dissenting opinion in the case.

Eoghan Keenan - 06/10/2005


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Issues and Causes of Action
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Issues
Affected Gender
Male
Crowding
Crowding / caseload
General
Assault/abuse by residents/inmates/students
Classification / placement
Food service / nutrition / hydration
Law library access
Recreation / Exercise
Sanitation / living conditions
Visiting
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Ohio Department of Correcctions
Plaintiff Description inmates in the Ohio correctional system
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 1977 - 1977
Case Closing Year 1981
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 ]

  Hard Judicial Choices: Federal District Court Judges and State and Local Officials
By: Phillip J. Cooper (State University of New York: Albany)
Citation: (1988)
[ 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 ]

  Rhodes v. Chapman Analyzed for Effect on Prison Overcrowding
By: Michael B. Mushlin (Pace Law School)
Citation: Nat'l Prison Project J., Winter 1987 at 4
[ Detail ]

Links The Oyez Project, Rhodes v Chapman, 452 U.S. 337 (1981)
www.oyez.org
Posted: Jun. 15, 1981
By: Oyez Project (IIT Chicago-Kent College of Law)
[ Detail ] [ External Link ]

Docket(s)
No docket sheet currently in the collection
General Documents
Findings of Fact and Conclusions of Law 06/29/1977 (434 F.Supp. 1007) (S.D. Ohio)
PC-OH-0003-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum Decision 06/06/1980 (624 F.2d 1099)
PC-OH-0003-0002.pdf | WESTLAW| LEXIS | Detail
Memorandum Decision 11/03/1980 (449 U.S. 951)
PC-OH-0003-0005.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
[Granting motion not to supplement Joint Appendix] 12/15/1980 (449 U.S. 1060)
PC-OH-0003-0003.pdf | WESTLAW| LEXIS | Detail
Supreme Court Decision 01/26/1981 (449 U.S. 1122)
PC-OH-0003-0007.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Supreme Court Decision 02/23/1981 (450 U.S. 906)
PC-OH-0003-0006.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Memorandum Decision 06/15/1981 (452 U.S. 337)
PC-OH-0003-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Hogan, Timothy Sylvester (S.D. Ohio)
PC-OH-0003-0001
Powell, Lewis Franklin Jr. (SCOTUS)
PC-OH-0003-0004
Monitors/Masters None on record
Plaintiff's Lawyers App, Robert P. (Ohio)
PC-OH-0003-0001
Barrows, Edward Clark (Ohio)
PC-OH-0003-0001
Friedman, Bruce (Ohio)
PC-OH-0003-0001
Jacobs, Louis A. (Ohio)
PC-OH-0003-0001
Kamp, Jean P. (Ohio)
PC-OH-0003-0004
Leventer, Jan (Ohio)
PC-OH-0003-0001
Rosenberg, Howard J. (Ohio)
PC-OH-0003-0001
Stanley, Christopher D. (Ohio)
PC-OH-0003-0001
Twohig, R. Raymond Jr. (Ohio)
PC-OH-0003-0001
Defendant's Lawyers Adler, Allen Paul (Ohio)
PC-OH-0003-0001 | PC-OH-0003-0004
Conway, Leo J. (Ohio)
PC-OH-0003-0001
Other Lawyers None on record

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