On March 8, 1983, inmates at the Morgan County Jail in Alabama filed a class action lawsuit pro se under 42 U.S.C. § 1983 in the U.S. District Court for the Northern District of Alabama against Department of Corrections officials challenging the overcrowded conditions of the jail. The complaint alleged crowding, lack of adequate medical attention, lack of a grievance procedure, lack of a library, denial of religious freedom, unsanitary food, and failure to transfer inmates to state institutions following sentencing. The court appointed counsel for the plaintiff class. Over the next two years, vigorous discovery ensued, and on November 23, 1985, the court certified the case as a class action.

Nearly three years after the case was filed, the parties presented a consent decree, which was approved by the court on March 13, 1986. Under the decree, the Alabama Department of Corrections and the Commissioner of the Alabama Department of Corrections were ordered to transfer state prisoners from the county jail to state facilities within a certain amount of time after conviction.

On February 20, 1997, the Morgan County Sheriff and the County filed a motion to enforce the decree and the State filed a motion to modify the decree. The Court found the State in contempt for violating the decree, ordered that the State pay fines and attorneys' fees, and the State appealed.

On June 18, 1998 the United States Court of Appeals for the Eleventh Circuit (Judge James Larry Edmondson) reversed and remanded, holding that the district court applied the wrong standards to assess the State's ability to comply with the decree, and also holding that certain evidence was improperly excluded from consideration. Chairs v. Burgess, 143 F.3d 1432 (11th Cir. 1998). On remand, the district court (Judge U.W. Clemon) held that the State had not made reasonable, good faith efforts to comply with the decree, that the contempt judgment was appropriate, and that the attorneys for the class and county were entitled to fees. Chairs v. Burgess, 25 F.Supp.2d 1333 (N.D.Ala. 1998). The court further dissolved the consent decree and terminated the case without prejudice to the plaintiffs' ability to pursue state law claims.

Rebecca Bloch - 04/23/2006


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