University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Cagle v. Hutto PC-VA-0002
Docket / Court 79-515 ( E.D. Va. )
State/Territory Virginia
Case Type(s) Prison Conditions
Case Summary
Sometime in 1979, an inmate at the Powhatan Correctional Center (PCC) filed a lawsuit under 42 U.S.C. § 1983 against the Virginia Department of Corrections in United States District Court in the Eastern District of Virginia alleging Eighth Amendment violations. Specifically, the inmate alleged ... read more >
Sometime in 1979, an inmate at the Powhatan Correctional Center (PCC) filed a lawsuit under 42 U.S.C. § 1983 against the Virginia Department of Corrections in United States District Court in the Eastern District of Virginia alleging Eighth Amendment violations. Specifically, the inmate alleged that the totality of the conditions at PCC amounted to cruel and unusual punishment. Similar inmate cases were consolidated with the Cagle case on January 15, 1980 and on February 19, 1980. Plaintiffs, represented by private counsel, sought compensatory and declaratory relief.

On June 18, 1980, the plaintiffs filed an amended complaint and moved for class certification. The class was certified on October 7, 1980 to include present and future inmates at the Powhatan Correctional Center. During a hearing on the inmates' motion for a preliminary injunction, the District Court (Judge David Dortch Warriner) found that there was a "pervasive risk of harm" to prisoners at PCC. Negotiations followed, and the parties entered into a Consent Decree which was approved by the District Court on February 12, 1981. The Decree provided various forms of injunctive relief and contemplated continued supervision by the District Court through the filing of periodic compliance reports.

On April 26, 1996, the President signed the Prison Litigation Reform Act, which stated that prospective relief in prison conditions cases "shall extend no further than necessary to correct the violation of the Federal right of a particular plaintiff or plaintiffs." 18 U.S.C. § 3626(a)(1).

On March 14, 1997, the defendants filed a motion to terminate Consent Decree. On May 14, 1998, the District Court (Judge James R. Spencer) granted defendants' motion and vacated the Consent Decree. The class of inmates appealed.

On May 28, 1999, the United States Court of Appeals for the Fourth Circuit (Judge William Walter Wilkins) affirmed, holding that: (1) the PLRA was constitutional; (2) the PLRA did not provide an avenue for district courts to make, post hoc and nunc pro tunc, the findings required by the Act in order to avoid termination of a consent decree; (3) state did not waive the right to obtain termination of the decree; (4) the PLRA did not mandate an evidentiary hearing in all cases; and (5) there was no abuse of discretion in refusing to conduct an evidentiary hearing in the instant case.

On June 26, 2000, the Supreme Court denied the plaintiff's petition for writ of certiorari.

Emilee Baker - 11/02/2006


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Issues and Causes of Action
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Issues
Crowding
Crowding / caseload
General
Assault/abuse by residents/inmates/students
Bathing and hygiene
Classification / placement
Education
Food service / nutrition / hydration
Recreation / Exercise
Sanitation / living conditions
Staff (number, training, qualifications, wages)
Totality of conditions
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Virginia Department of Corrections
Plaintiff Description Present and future inmates of the Powhatan Correctional Center in Virginia
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 Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1981 - 1998
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 ]

Docket(s)
No docket sheet currently in the collection
General Documents
Brief of Appellees 10/15/1998
PC-VA-0002-0001.pdf | Detail
Opinion 05/28/1999 (177 F.3d 253)
PC-VA-0002-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum Decision 06/26/2000 (530 U.S. 1264)
PC-VA-0002-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Hamilton, Clyde H. (Fourth Circuit, D.S.C.)
PC-VA-0002-0002
Wilkins, William Walter (Fourth Circuit, D.S.C.)
PC-VA-0002-0002
Wilkinson, James Harvie III (Fourth Circuit)
PC-VA-0002-0002
Monitors/Masters None on record
Plaintiff's Lawyers Starke, Karen Lee (Virginia)
PC-VA-0002-0002
Wolf, Thomas Marshall (Virginia)
PC-VA-0002-0002
Defendant's Lawyers Earley, Mark Lawrence (Virginia)
PC-VA-0002-0001 | PC-VA-0002-0002
Muse, William W. (Virginia)
PC-VA-0002-0001 | PC-VA-0002-0002
Other Lawyers None on record

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