On July 25, 1989, prisoners at the old Lassen County Jail ("Old Jail") filed a class action lawsuit in the U.S. District Court for the Eastern District of California against the County of Lassen and the Sheriff of the County of Lassen. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging that conditions in the Old Jail violated the First, Fourth and Eighth Amendments of the Constitution of the United States as applied to the states through the Fourteenth Amendment. Among other things, they alleged overcrowding, inadequate clothing, inadequate medical, dental and mental health care, inadequate privacy for conversations with attorneys, and unequal access to programs for women prisoners. Plaintiffs sought a broad set of injunctive remedies.
When the suit was filed, Lassen County was developing and implementing plans for construction of a new, much larger jail ("New Jail").
On October 17, 1989, the District Court approved a stipulated order preliminarily enjoining certain Old Jail conditions. Pursuant to the stipulated order, the County agreed to: (1) limit inmate population at the Old Jail to forty-one inmates; (2) limit the temporary holding cell's population to the rated capacity; (3) limit time spent in the temporary holding cell to eight hours; (4) comply with California law in its use of the detoxification facility; (5) provide all prisoners with a permanent bed appropriate to his/her classification; and (6) provide all prisoners with daily access to the "program room" and outdoor recreation.
Beginning on July 16, 1990, the case was tried before Magistrate Judge John F. Moulds. The trial concluded in September 1990. On July 1, 1991, the New Jail opened and the County ceased using the Old Jail.
On August 1, 1991, Magistrate Judge Moulds entered his 129-page findings and recommendations. On September 17, 1991, District Judge Lawrence K. Karlton entered an order adopting the findings and recommendations, with one minor modification. The order granted the following relief: (1) For a period of one year, the County was prohibited from exceeding the established inmate capacities at the Old Jail or the New Jail; (2) The County was required to "modify" and follow written policies regarding access to the jail law library; (3) The County was required to clarify the procedures for staff handling of prisoners demonstrating a mental disorder; (4) The County was required to develop a procedure for ensuring a timely response to an inmate's request for mental health care. All further requests for relief were denied. On October 9, 1991, Judge Karlton entered a judgment. On November 7, 1991, the defendants filed their notice of appeal from the judgment.
The attorney's fees litigation then commenced, with both sides seeking attorney's fees. On March 30, 1993, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue. On April 20, 1993, Judge Karlton filed an order adopting the finding and recommendations in full. This order granted the plaintiffs some of the attorney's fees they had sought, for a total of $219,027.61, and denied the defendants' request for fees. On April 27, 1993, Judge Karlton entered his Judgment pursuant to the attorney's fees order. On April 28, 1993, the appellants filed their notice of appeal from the attorney's fees order, and the award was stayed pending appeal.
On October 6, 1994, a three-judge panel of the Ninth Circuit (Circuit Judges Arthur L. Alarcon and Ferdinand F. Fernandez and District Judge Stephen V. Wilson, sitting by designation) reversed the District Court's decision to grant permanent injunctive relief but affirmed its decision that attorney's fees were appropriate. Doty v. Cnty. of Lassen
, 37 F.3d 540 (9th Cir. 1994). The panel, in an opinion by Judge Wilson, found that the injunction as a whole was erroneous because there was no evidence of constitutional violation at the New Jail. It also found, however, that since the plaintiffs had succeeded in obtaining a preliminary injunction and had catalyzed other reforms at the jails, they were "prevailing parties" under 42 U.S.C. § 1988 and could be awarded reasonable attorney's fees; it therefore vacated the District Court's award and remanded for redetermination in light of plaintiffs' limited success.
On remand, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue on July 26, 1995, and Judge Karlton adopted them in full on September 19, awarding plaintiffs a total of $83,616.75. On the same day, Judge Karlton entered judgment in favor of the defendants per the order of the Court of Appeals.
(This summary is adapted in part from the Appeals Court's discussion of the background of the case. See Doty
, 37 F.3d at 542.)Christopher Schad - 07/11/2012