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Case Name Hoptowit v. Spellman PC-WA-0010
Docket / Court 79-0359 ( E.D. Wash. )
State/Territory Washington
Case Type(s) Prison Conditions
Case Summary
On October 12, 1979, inmates at the Washington State Penitentiary brought a class-action lawsuit in the United States District Court for the Eastern District of Washington under 42 U.S.C. § 1983 alleging that conditions in the facility amounted to cruel and unusual punishment. Plaintiffs were ... read more >
On October 12, 1979, inmates at the Washington State Penitentiary brought a class-action lawsuit in the United States District Court for the Eastern District of Washington under 42 U.S.C. § 1983 alleging that conditions in the facility amounted to cruel and unusual punishment. Plaintiffs were represented by Columbia Legal Services in Seattle and private attorneys. (On appeal, the plaintiffs were represented by the American Civil Liberties Union of Washington.) The district court (Judge Jack E. Tanner) found that the penitentiary was constitutionally deficient and awarded injunctive relief. The district court opinions are not available for this case.

On appeal, the United States Court of Appeal for the Ninth Circuit (Judge John C. Wallace) found that the district court erred in holding that overcrowding was a constitutional violation. Hoptowit v. Ray, 682 F.2d 1237 (9th Cir. 1982). The Ninth Circuit affirmed the district court's holding that the medical services provided at the penitentiary violated the Eighth Amendment but held that the court erred in finding constitutional violations in the areas of vocational and educational programs, the physical conditions of the facility, segregation of inmates, and lockdown conditions. In these areas, the district court had taken what the Ninth Circuit found to be an erroneous "totality of conditions" approach and did not consider and provide remedies for individual violations. The Ninth Circuit also found that the district court's decision that inmates lacked access to courts and were retaliated against when seeking access was not based on sufficient findings of fact. The case was remanded.

On remand, the district court (Judge Jack Edward Tanner) again entered judgment finding conditions to be in violation of the Eighth amendment and ordered relief. On appeal, the Ninth Circuit (Judge Benjamin Duniway) held that the district court followed its previous instructions to consider the findings of fact individually. Hoptowit v. Spellman, 753 F.2d 779 (9th Cir. 1985). It upheld the district court's determination that the conditions related to the physical conditions of the facility, fire safety, protective custody, and segregation were unconstitutional but vacated two provisions of the court's order. These provisions required officials to provide inmates with adequate food and clothing. The Ninth Circuit vacated these provisions because there had been no findings of fact related to food or clothing. The case was remanded.

The PACER docket for this case begins in 1996, so there is no information regarding proceedings between 1985 and 1996. In 1996, defendants moved to reopen the case and vacate the permanent injunction. The district court (Judge William Nielson) ordered the parties to brief the applicability of the Prison Litigation Reform Act in this case. The parties negotiated a settlement and the court directed notice to the members of the class on August 14, 1997. The court received comments from plaintiffs. On August 19, 1999, Judge Nielson approved the parties' proposed settlement, which was finalized in a "Memorandum of Understanding" that is unavailable, and dismissed the case, retaining jurisdiction to adjudicate issues concerning attorneys fees.

Angela Heverling - 04/05/2006


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Issues and Causes of Action
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Issues
General
Administrative segregation
Classification / placement
Education
Food service / nutrition / hydration
Recreation / Exercise
Sanitation / living conditions
Totality of conditions
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Washington State Department of Corrections
Plaintiff Description inmates at the Washington State Penitentiary
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 Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1999
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)
79-359 (E.D. Wash.) 08/28/2000
PC-WA-0010-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Reported Opinion 02/16/1982 (682 F.2d 1237)
PC-WA-0010-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Reported Opinion 02/12/1985 (753 F.2d 779)
PC-WA-0010-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Duniway, Benjamin Cushing (Ninth Circuit)
PC-WA-0010-0002
Nielsen, William Fremming (E.D. Wash.)
PC-WA-0010-9000
Wallace, John Clifford (Ninth Circuit, S.D. Cal.)
PC-WA-0010-0001
Monitors/Masters None on record
Plaintiff's Lawyers Blumberg, Richard P. (Washington)
PC-WA-0010-0002
Burman, David J. (Washington)
PC-WA-0010-9000
Diamondstone, Fred (Washington)
PC-WA-0010-9000
Ford, Timothy K. (Washington)
PC-WA-0010-0002 | PC-WA-0010-9000
Midgley, John (Washington)
PC-WA-0010-0001
Stalker, Robert A. Jr. (Washington)
PC-WA-0010-9000
Defendant's Lawyers Blonien, John Scott (Washington)
PC-WA-0010-9000
Carr, Douglas Wayne (Washington)
PC-WA-0010-9000
Collins, William C. (Washington)
PC-WA-0010-0001 | PC-WA-0010-0002
Smith, Carol A. (Washington)
PC-WA-0010-0001
Other Lawyers None on record

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