On March 23, 1993, plaintiffs, a class of prisoners incarcerated at the Fresno County Jail, filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of California, Sacramento Division. The plaintiffs, represented by private counsel, sought declaratory and injunctive relief, alleging violations of their First, Fourth, Fifth, Eighth, and Fourteenth Amendment rights by the Fresno County Jail. Specifically, plaintiffs claimed that the overcrowding due to construction and simple overcrowding made the conditions in the jail unconstitutional under the Eighth Amendment and the Fourteenth Amendment, and led to deprivation of their other constitutional rights.
The Fresno County Jail is split into three parts: The Main Jail, the North Annex, and the South Annex. At the time plaintiffs made their complaint, the third and fourth floors of the South Annex were being remodeled, requiring jail staff to relocate 434 inmates that were housed there to the North Annex and the Main Jail, leading to severe overcrowding.
As a result, the prison also restricted access to exercise, recreation, religious activities, and the law library. Prisoners were allowed one hour per week for legal research, and two trips per week to a facility that doubled as a space for religious activities. The exercise space was also alleged to not contain enough equipment or room for plaintiffs to adequately exercise.
The plaintiffs alleged that the South Annex, rated for 511 prisoners, was housing over 700. The plaintiffs also alleged that 300 prisoners were sleeping on the floor in the Main Jail, in the common areas, and that the solitary confinement unit had 3 prisoners per cell. They also alleged that the North Annex had 200 prisoners that slept on the floor.
On February 25, 1993, the plaintiffs filed a motion for a temporary restraining order that would require the defendants to add beds and ensure that no prisoner slept on the floor, and allow compliance monitoring.
On March 9, 1993, the defendants admitted the class status of the plaintiffs and agreed that they currently were exceeding their capacity in the jail system, but denied that it was unconstitutionally overcrowded. However, before the Court could rule on the TRO and the certification motion, the parties reached a consent decree.
On May 25, 1993, the consent decree was modified to give more detail concerning the exact number of beds in each cell block in each facility, and to give the Sheriff the power to release or to refuse to house prisoners when the jail system was at 90% capacity.
On November 3, 1993, the consent decree was again modified to reflect transition of the housing in the jail under a state pilot program into a triple-bunked "general population," double-bunked "special population," and single-bunked "administrative segregation" scheme. The consent decree specifically reserved the issues of law library access and adequacy of exercise for trial.
On February 25, 1994, the parties settled the outstanding recreational issues, providing for one-hour of exercise a day, and up to 20 hours a month, with 1.5 hours being roof-recreation. A few months later, the Court entered a final order approving the settlement agreement and placing the Fresno County Jail under a permanent injunction.
On July 14, 2011, the Fresno County Superior Court filed a motion to intervene in the case. The state court system alleged that, because the Fresno County Jail had closed two floors, the consent decree could not be maintained, and the ability to sentence defendants consistent with California law had been adversely affected.
On December 5, 2011, the defendants and plaintiffs reached another consent decree clarifying the meaning of the word "capacity" in the original consent decree rendering the defendant-intervenor's contentions moot. The Court thereafter denied the State Court's motion to intervene as moot.
This case is still open because of the permanent injunction running against the Fresno County Jail. The plaintiffs also moved for attorney fees, though the Court denied the motion on May 31, 2012. As of January 31, 2018, there has not been any new meaningful litigation.
Blase Kearney - 06/18/2012
Maurice Youkanna - 07/05/2014
compress summary
