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Case Name Castillon v. Correction Corporation of America PC-ID-0009
Docket / Court 1:12-cv-00559 ( D. Idaho )
Additional Docket(s) [ 17-35896 ]  Federal Court of Appeals
State/Territory Idaho
Case Type(s) Prison Conditions
Case Summary
On November 9, 2012, 8 inmates at the Idaho Correctional Center (ICC) filed a lawsuit in the District of Idaho. The plaintiffs sued Corrections Corporation of America (CCA), which operates the Idaho Correctional Center, under 42 U.S.C § 1983 for violations of their Eighth and Fourteenth Amendment ... read more >
On November 9, 2012, 8 inmates at the Idaho Correctional Center (ICC) filed a lawsuit in the District of Idaho. The plaintiffs sued Corrections Corporation of America (CCA), which operates the Idaho Correctional Center, under 42 U.S.C § 1983 for violations of their Eighth and Fourteenth Amendment rights under the color of state law. The plaintiffs, represented by private counsel, sought compensatory damages and punitive damages. The plaintiffs also sought injunctive relief and an award of attorney’s fees and costs at the court's discretion. The plaintiffs claimed that they had been victims of a gang assault in which six members from the Aryan Knights and the Severely Violent Criminals hid in a closet in order to attack the plaintiffs with shivs and shanks. The plaintiffs alleged that the defendant used gang violence as a way to gain control over the inmate population and decrease operating costs. Specifically, the plaintiffs alleged that the defendant purposefully housed members of the same gang in the same block (creating what prisoners called a gang-controlled walk); operated at or above maximum capacity; and maintained an insufficient numbers of guards, which created a substantial risk of gang violence, pressure to join gangs, and pressure to participate in gang activities in and outside of the prison. Pictures, video of the attack, and other documents can be found on the plaintiff's lawyers' website. This case was assigned to Judge Dee V. Benson and referred to Judge Mikel H. Williams for settlement negotiations.

On January 14, 2013, the defendant moved to dismiss the complaint. The defendant stated that (1) six of the eight plaintiffs failed to exhaust their administrative remedies as required under the Prison Litigation Reform Act (PLRA); (2) the Complaint failed to allege with factual specificity the basis for a policy or custom violation; and (3) the complaint contained numerous immaterial and improper allegations.

On January 18, 2013, the plaintiffs filed an amended complaint as a result of an anonymous email from a member of the prison staff that alleged that the defendant had been falsifying its records to make it appear that the various blocks were fully staffed and in compliance with a settlement agreement from a previous case, Kelly v. CCA, PC-ID-0007.

On June 4, 2013, the court granted in part and denied in part the defendant’s motion to dismiss because the warden had suggested that the plaintiffs had exhausted internal remedy procedures. For six plaintiffs, the court ruled that they could have reasonably believed that there were no additional steps for them to take in pursuing compensation within the prison system. The assistant warden had previously approved a decision that if the plaintiffs had wanted to pursue compensation, they could do so "utilizing outside sources." Therefore, the plaintiffs partial exhaustion of the grievance process was sufficient to meet PLRA requirements. The six plaintiffs were allowed to proceed and had stated a plausible claim for relief based on the ghost worker allegation and gang member placement. But two plaintiffs' claims were dismissed because they had not yet exhausted available grievance procedures, and the case became Knight v. CCA (however, because the case continued to be referred to by its previous name, we have retained the named plaintiff above).

On June 21, 2013 a collection of media entities (referred to as the Media Coalition) filed a motion to intervene in the proceedings so that it could oppose the defendant’s proposed protective order on the grounds that it would interfere with the press's ability to gather and report news. On August 6, 2013, the Media Coalition’s motion to intervene was granted. The court held that the protective order was necessary to ensure both the defendant’s employees’ safety and the plaintiffs’ safety. The court deemed \ this information unhelpful to the plaintiffs in their lawsuit.

The parties began extensive discovery negotiations. However, upon a finding that the parties “refused to interact with each other reasonably and civilly,” the court referred the case for discovery mediation. On November 15, 2013, the parties filed a stipulation on certain discovery issues.

This stipulation did not resolve all of the parties’ discovery disputes. On February 7, 2014, the court denied the plaintiff’s motion to compel for discovery requests related to the defendant’s wage data and incentive plans (such as bonus reports). The court concluded that the plaintiffs had access to this information and that the request was frivolous. The court threatened awarding the defendant its attorneys’ fees should the plaintiffs continue to engage in abusive discovery practices. The court also held that they would not consider any more motions to compel by either party unless the parties’ attorneys had met face-to-face in at least one conference lasting at least two hours where they genuinely attempted to resolve each aspect of the motion to compel.

On March 10, 2014, the defendants filed a motion to stay discovery after the FBI announced its intention to institute a criminal investigation into the defendant’s alleged conduct. On March 19, 2014, the court denied this motion. The court held that the plaintiffs’ interests in avoiding delay on a case that is nearly two-years old was greater than the highly speculative burden the investigation would pose to the defendant.

On September 2, 2014, the plaintiffs’ moved for partial summary judgment on the defendant’s widespread custom of gang clustering and understaffing mandatory posts, the defendant’s affirmative defenses, and the defendant’s failure to respond to the plaintiff’s contention interrogatories regarding these affirmative defenses. On September 15, 2014, the defendant moved for summary judgment or partial summary judgement in the alternative on the plaintiff’s claim for punitive damages. On June 29, 2015, the court denied the plaintiffs’ motion for summary judgement. The court held that the plaintiffs’ request did not comply with the Federal Rules of Civil Procedure.

On December 3, 2015, Magistrate Candy Dale issued a Report and Recommendation that the defendant’s motion for summary judgment be granted. The court concluded that no reasonable jury could conclude that the defendant was aware that its staffing or housing policy posed a risk to the plaintiffs. On December 21, 2015, the plaintiffs objected to the Report and Recommendation. And on July 7, 2016, the district court rejected portions of the reports that granted the defendant’s motion for summary judgement with respect to the understaffing claim and municipal liability. The court granted the defendant’s motion for summary judgement on the plaintiffs’ “gang clustering theory.”

On September 15, 2016, the defendants filed a motion for reconsideration of the court’s order with respect to the plaintiffs’ understaffing claim. On November 10, 2016, the court denied reconsideration. The court found that the plaintiffs had adequately established Monell causation regarding the relationship between understaffing and their assault. The parties prepared for trial.

Trial began on February 13, 2017 and continued through February 22, 2017. On February 22, 2017, the defendant moved for a directed verdict. The court denied the defendant’s motion and took under advisement their motion to dismiss for punitive damages.

On February 23, 2017, the jury returned a special verdict. The jury found that the defendant was deliberately indifferent to a substantial risk of serious harm to the plaintiffs. The defendant disregarded this risk by failing to take reasonable measures to address it, which violated their Eighth Amendment rights. The jury also found that the defendant had a widespread practice and custom of understaffing at ICC. However, the jury did not find that the practice of understaffing caused a deprivation of the plaintiffs’ Eighth Amendment rights on the day of the assault. So, it did not award the plaintiffs compensatory or punitive damages.

On June 8, 2017, the plaintiffs filed motions to alter or amend the judgment and for a new trial. The next day, the defendant also filed motions to alter or amend the judgment and for a new trial. The court denied both of the plaintiffs’ motions. It held that the jury instructions correctly delineated the elements necessary to prove causation and that the plaintiffs failed to object to jury instructions, thereby waiving their right to appeal. Regarding the plaintiffs claim that the special verdict form was superfluous and inconsistent, the court disagreed. The court also found that the plaintiffs had failed to object to its inclusion and therefore had no right to object. The court granted the defendant’s motion to alter the judgement to state “Judgment is entered in favor of Defendant, with Plaintiffs to take nothing.”

On November 2, 2017, the plaintiffs appealed to the U.S. Court of Appeals for the Ninth Circuit. On May 18, 2018, this appeal was voluntarily dismissed for reasons unknown. This case is now closed.

Kenneth Gray - 07/10/2013
Hannah Greenhouse - 10/30/2018


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Crowding
Crowding / caseload
Defendant-type
Corrections
General
Assault/abuse by residents/inmates/students
Conditions of confinement
Failure to discipline
Failure to supervise
Staff (number, training, qualifications, wages)
Plaintiff Type
Private Plaintiff
Type of Facility
Non-government for profit
Causes of Action 42 U.S.C. § 1983
Defendant(s) Corrections Corporation of America
Plaintiff Description Eight inmates victims at Idaho Correction Correctional Center of a gang-planned assault carried out by six inmates from the Aryan Knights and the Severely Violent Criminals
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Filing Year 2012
Case Closing Year 2018
Case Ongoing No
Additional Resources
click to show/hide detail
  Inmates v. CCA in Idaho
Angstman, Johnson, and Associates
Date: Jul. 10, 2013
By: Angstman Johnson
[ Detail ] [ External Link ]

  Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
Date: May 2006
By: Margo Schlanger (Washington University Faculty)
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
Book
Date: Jan. 1, 1998
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
1:12-cv-559 (D. Idaho)
PC-ID-0009-9000.pdf | Detail
Date: 05/18/2018
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Damages, and for Declaratory and Injunctive Relief [ECF# 1]
PC-ID-0009-0001.pdf | Detail
Date: 11/09/2012
Source: PACER [Public Access to Court Electronic Records]
First Amended Complaint for Damages, and for Declaratory and Injunctive Relief [ECF# 14]
PC-ID-0009-0002.pdf | Detail
Date: 01/18/2013
Source: PACER [Public Access to Court Electronic Records]
Order [ECF# 44] (2013 WL 2446480) (D. Idaho)
PC-ID-0009-0003.pdf | WESTLAW | Detail
Date: 04/19/2013
Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order [ECF# 54] (D. Idaho)
PC-ID-0009-0004.pdf | Detail
Date: 06/04/2013
Source: PACER [Public Access to Court Electronic Records]
Report and Recommendation [ECF# 231]
PC-ID-0009-0005.pdf | Detail
Date: 12/03/2015
Source: PACER [Public Access to Court Electronic Records]
Order on Report and Recommendation [ECF# 236] (2016 WL 3676116) (D. Idaho)
PC-ID-0009-0006.pdf | WESTLAW | Detail
Date: 07/07/2016
Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order [ECF# 260] (D. Idaho)
PC-ID-0009-0007.pdf | Detail
Date: 11/10/2016
Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order [ECF# 373] (2017 WL 4507244) (D. Idaho)
PC-ID-0009-0008.pdf | WESTLAW | Detail
Date: 10/06/2017
Source: PACER [Public Access to Court Electronic Records]
Judges Benson, Dee Vance (D. Utah, FISC)
PC-ID-0009-0008 | PC-ID-0009-9000
Dale, Candy W. (D. Idaho) [Magistrate]
PC-ID-0009-0005
Lodge, Edward J. (D. Idaho)
PC-ID-0009-0003 | PC-ID-0009-0004 | PC-ID-0009-0006 | PC-ID-0009-0007
Williams, Mikel H. (D. Idaho) [Magistrate]
PC-ID-0009-9000
Plaintiff's Lawyers Angstman, Thomas J. (Idaho)
PC-ID-0009-0001 | PC-ID-0009-0002 | PC-ID-0009-9000
Brown, Charles A. (Idaho)
PC-ID-0009-9000
Johnson, Wyatt Benton (Idaho)
PC-ID-0009-0002 | PC-ID-0009-9000
Shallat, Anthony (Idaho)
PC-ID-0009-9000
Smith, Nikki Rachelle (Idaho)
PC-ID-0009-0002 | PC-ID-0009-9000
Defendant's Lawyers Naylor, Jacob H. (Idaho)
PC-ID-0009-9000
Naylor, Kirtlan G. (Idaho)
PC-ID-0009-9000
Stoll, James R. (Idaho)
PC-ID-0009-9000
Struck, Daniel Patrick (Arizona)
PC-ID-0009-9000
Zoellner, Tara B. (Arizona)
PC-ID-0009-9000

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