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Case Name Stewart v. Gates JC-CA-0054
Docket / Court 2:75-cv-03075 ( C.D. Cal. )
State/Territory California
Case Type(s) Jail Conditions
Special Collection California Jail Population Caps
Attorney Organization Hadsell, Stormer & Renick
Case Summary
In 1975, pretrial detainees in the Orange County Jail filed a lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the Central District of California, challenging the conditions of confinement at the Orange County Jail. Attorneys with the ACLU Foundation of Southern ... read more >
In 1975, pretrial detainees in the Orange County Jail filed a lawsuit pursuant to 42 U.S.C. § 1983 in the United States District Court for the Central District of California, challenging the conditions of confinement at the Orange County Jail. Attorneys with the ACLU Foundation of Southern California represented Plaintiffs.

In 1978, the District Court (Judge William P. Gray) found unconstitutional conditions of confinement at the jail and issued injunctive relief ordering reforms be implemented in a number of areas. including: telephone access, visitation, law library access, mail, religious exercise, administrative segregation, meals, and sleeping accommodations. Stewart v. Gates, 450 F. Supp. 583 (C.D. Cal. 1978), remanded by Stewart v. Gates, 618 F.2d 117 (9th Cir. 1980). Judge Gray awarded attorney fees to Plaintiffs' counsel, but the Ninth Circuit Court of Appeals reversed and remanded the case for recalculation of fees. Stewart v. Gates, 987 F.2d 1450 (9th Cir. 1993) (Circuit Judge Robert R. Beezer).

At some point during the 1980s, a population cap and other remedial orders were added. Other than the issue of fees, we have little information on case activity from 1980 to 2003, when memoranda were filed by the Court's ombudsman and Plaintiffs alleging violations of the Court's orders.

On March 11, 2004, the District Court (Judge Gary L. Taylor) consolidated the case with Pierce v. County of Orange, No. 8:01-cv-00981 [JC-CA-0046]. On April 27, 2005, relying upon the 1996 Prison Litigation Reform Act and case law emphasizing prison administrators discretion, Judge Taylor vacated the previously entered remedial orders and dismissed the case.

Plaintiffs appealed, and on March 23, 2008, the U.S. Court of Appeals for the Ninth Circuit (Judge Betty B. Fletcher) partially reversed the district court's decision, ruling that the district court could not terminate its previous orders securing minimal access to religious services and exercise. The Court of Appeals also ruled that the County was in violation of the ADA because of disparate programs and services that were offered to disabled versus non-disabled inmates. The case was remanded for further fact-finding on the state of physical barriers to adequate access to bathrooms, showers, exercise areas, dayrooms, dining rooms, cells and all other areas to which disabled persons should have access, and to order remedial remedies as required.

On January 7, 2011, after a six-day bench trial, the Court (Judge Audrey B. Collins) confirmed the ADA sub-class as pretrial detainees with either a "mobility" or "dexterity" impairment, and made detailed findings of fact as to the conditions in the various facilities. After the parties offered proposed plans and comments, the Court entered judgment for the plaintiffs on June 28, 2011, accepting the defendant's final proposed plan for addressing the physical barriers identified in the factual findings and ensuring that disabled detainees were provided with equal access to programs, services, and activities as discussed therein.

Over the next year, the parties fought over attorneys' fees and issues regarding the Orange County Jail's compliance with the judgment. On February 10, 2014, Judge Collins terminated the ongoing order and injunctive relief, having found that the injunction was no longer necessary because the three areas in which plaintiffs sought to extend the injunction did not present current or ongoing violations and thus continued monitoring was no longer necessary.

Timothy Shoffner - 07/06/2012

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Issues and Causes of Action
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Affected Gender
Crowding / caseload
Pre-PLRA Population Cap
Administrative segregation
Law library access
Recreation / Exercise
Religious programs / policies
Search policies
Plaintiff Type
Private Plaintiff
Type of Facility
Causes of Action 42 U.S.C. § 1983
Defendant(s) Board of Supervisors of the County of Orange
Orange County Sheriff's Department
Plaintiff Description Prisoners of the Orange County Central Jail challenging policies and practices of administrators of jail.
Indexed Lawyer Organizations Hadsell, Stormer & Renick
Class action status sought Yes
Class action status granted Yes
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Order Duration 1978 - 2014
Filed 1975
Case Closing Year 2014
Case Ongoing No
Case Listing JC-CA-0046 : Pierce v. Orange County (C.D. Cal.)
JC-CA-0078 : Benson v. County of Orange (C.D. Cal.)
Additional Resources
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  See this case at (May provide additional documents and, for active cases, real-time alerts)
2:75-cv-03075-GLT (C.D. Cal.)
JC-CA-0054-9000.pdf | Detail
Date: 02/10/2014
Source: PACER [Public Access to Court Electronic Records]
General Documents
Memorandum of Decision (450 F.Supp. 583) (C.D. Cal.)
JC-CA-0054-0009.pdf | WESTLAW| LEXIS | Detail
Date: 05/03/1978
Source: Google Scholar
[Ninth Circuit] Opinion [Reversing and Remanding the District Court's Award of Attorneys' Fees] (987 F.2d 1450)
JC-CA-0054-0004.pdf | WESTLAW| LEXIS | Detail
Date: 03/12/1993
Order Vacating Earlier Orders and Dismissing Case [ECF# 20] (C.D. Cal.)
JC-CA-0054-0001.pdf | Detail
Date: 04/27/2005
Source: PACER [Public Access to Court Electronic Records]
Amended [Ninth Circuit] Opinion [Affirming the Termination of All but Two of the Extant Orders] (526 F.3d 1190)
JC-CA-0054-0002.pdf | WESTLAW| LEXIS | Detail
Date: 05/15/2008
Source: PACER [Public Access to Court Electronic Records]
Order [Regarding] Preliminary Trial Issues [ECF# 63] (C.D. Cal.)
JC-CA-0054-0003.pdf | Detail
Date: 05/07/2010
Source: PACER [Public Access to Court Electronic Records]
Findings of Fact and Conclusions of Law [Ordering the County to Remedy ADA Violations] [ECF# 67] (761 F.Supp.2d 915) (C.D. Cal.)
JC-CA-0054-0006.pdf | WESTLAW| LEXIS | Detail
Date: 01/07/2011
Source: PACER [Public Access to Court Electronic Records]
Order on Defendant's Amended Final Plan Submitted Pursuant to the Court's June 27, 2011 Order [ECF# 75] (C.D. Cal.)
JC-CA-0054-0007.pdf | Detail
Date: 06/28/2011
Source: PACER [Public Access to Court Electronic Records]
Order Re Amendments to Clarify Language in the Court's June 28, 2011 Final Order on Defendant's Proposed Plan [ECF# 82] (C.D. Cal.)
JC-CA-0054-0008.pdf | Detail
Date: 07/30/2012
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Beezer, Robert R. (Ninth Circuit) show/hide docs
Collins, Audrey B. (C.D. Cal.) show/hide docs
JC-CA-0054-0003 | JC-CA-0054-0006 | JC-CA-0054-0007 | JC-CA-0054-0008 | JC-CA-0054-9000
Fletcher, Betty Binns (Ninth Circuit) show/hide docs
Gray, William Percival (S.D. Cal., C.D. Cal.) show/hide docs
Taylor, Gary L. (C.D. Cal.) show/hide docs
Plaintiff's Lawyers Baltodano, Hernaldo J. (California) show/hide docs
Herman, Richard P. (California) show/hide docs
Jakes, Jill (California) show/hide docs
Keeny, Christy Virginia (California) show/hide docs
Litt, Barrett S. (California) show/hide docs
Miller, Bryan Barnet (California) show/hide docs
Okrand, Fred (California) show/hide docs
Smerling, Terry (California) show/hide docs
Stormer, Dan Lewis (California) show/hide docs
Defendant's Lawyers Choi, Jin S (California) show/hide docs
Golden, Jack W. (California) show/hide docs
Kuyper, Adrian (California) show/hide docs
Lawrence, David D. (California) show/hide docs
Miller, Steven C. (California) show/hide docs
Phillips, Wendy J. (California) show/hide docs
Sprenger, Christina M. (California) show/hide docs
Wahlstedt , Arthur C. (California) show/hide docs

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