On January 18, 1974, inmates of the St. Louis City Jail filed a class action lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Missouri against the City of St. Louis, its Department of Public Safety, and the St. Louis Sheriff. The plaintiffs, represented by private counsel and the American Civil Liberties Union of Eastern Missouri, sought injunctive relief, alleging that overcrowding at the St. Louis City Jail produced conditions which violated the inmates' constitutional rights. The United States initially participated as amicus curiae.
On October 2, 1974, the United States District Court for the Eastern District of Missouri (Judge John K. Regan) ordered the closure of the St. Louis City Jail. The court stayed its order for 30 days to allow the city to improve conditions at the jail. To avoid closure, the court ordered the St. Louis Jail (1) to have two guards on each floor at all times, (2) to follow cell occupancy limits, (3) to cease giving inmates authority over one another, and (4) to promptly transport sick and injured inmates to medical facilities. The court also capped jail capacity at 228 prisoners.
The City appealed. The file contains internal documents showing that the United States considered filing an amicus curiae brief to represent the federal government's interest in litigation involving a recently surveyed facility. On the court's order, the United States' status was changed from amicus curiae to intervener for the plaintiff on December 10, 1974.
On December 29, 1975, the court denied motions by the United States to enjoin the city (1) from transferring prisoners from the St. Louis City Jail to other facilities in the county and (2) to improve visitation and recreation for inmates. First, the United States challenged the practice of housing overflow detainees at Central Police Holdover because conditions at Holdover were more restrictive than at the jail. Second, the United States alleged that visitation facilities and recreational opportunities were too scarce for all inmates to enjoy their benefits.
The Assistant Attorney General for the Civil Rights Division of the Department of Justice initially recommended that the United States appeal the denial on March 1, 1976. By April 20, 1976, it appears that the Department of Justice had abandoned that plan because to appeal would be effectively to ask the court to hold the St. Louis Jail to higher standards than 90% of the facilities operated by the Federal Bureau of Prisons. On March 29, 1977, the Civil Rights Division recommended the case be closed, which was done on April 7, 1977.
On September 19, 1977, the matter was reopened for investigation of alleged double-celling. The Department of Justice chose not to pursue the allegations because double-celling had ended when the jail finished remodeling its facilities.
In 1982, the plaintiffs asked the court to hold the defendants in contempt of court for housing more than 228 prisoners at the St. Louis Jail. During evidentiary hearings, it became apparent that the St. Louis Jail still regularly housed overflow inmates at the Holdover. The court concluded that Holdover had effectively become an extension of the jail and, therefore, was subject to the terms of the injunction. Conditions in the overflow facilities, however, fell far below the mark. For instance, prisoners at Holdover could not wash their hands or shower, had no beds to sleep on, and were given neither towels nor toilet paper. Prisoners also lacked clean clothing, bedding, and toothbrushes.
On September 4, 1984, the court (Judge Clyde S. Cahill, Jr.) ordered that Holdover be closed as a jail facility and decreed that no prisoner would be held at Holdover for more than twenty-four hours. Tyler v. United States v. Schweitzer, 602 F. Supp. 476 (E.D. Mo. 1984). Although the court found the City in contempt, it concluded that a court order was not necessary because the City had already voluntarily taken remedial steps. The court also set a new population cap for the St. Louis City Workhouse, which it thought could be used to house jail overflow. The court awarded the plaintiffs attorney's fees and costs.
On April 11, 1990, the court increased the population cap for the St. Louis City Workhouse from 450 inmates to 481. Tyler v. United Stats v. Murphy, 737 F. Supp. 531 (E.D. Mo. 1990). The court mandated increases in staff and ordered the city to maintain per-inmate food, clothing, medical and dental expenditures. The court also ordered the City to submit a plan for electronic shackling and house arrest. The court discussed the social problems that contribute to jail overcrowding and suggested that simply building more jails would not necessarily resolve the problem. The court suggested that jail overcrowding could be addressed by expediting criminal trials, increasing the use of bail bonds, home arrest, and closing the jail to military arrestees, parole violators, and convicts awaiting other trials.
From 1993 to 1994, the court considered the problem that parole violators posed for already overcrowded jails. The court placed caps on the number of parole violators who could be housed at the Workhouse. In 1994, the United States Court of Appeals for the Eighth Circuit ordered the lower court to reconsider the cap on parole violators. On September 16, 1996, the District Court issued an order capping at twenty the number of parole violators who could be detained at the Workhouse. The court's order required the Workhouse to release parole violators arrested after the facility was at capacity, even if open beds were available. When the district court refused the St. Louis Sheriff's request to dissolve the injunction pursuant to the Prison Litigation Reform Act (PLRA), the Sheriff appealed. On February 5, 1998, the Eighth Circuit (Judge James B. Loken) reversed, holding that the injunction should be dissolved under the PLRA because it predated the PLRA. Tyler v. Murphy, 135 F.3d 594 (8th Cir. 1998).
In April 1999, the City of St. Louis announced that the St. Louis City Jail would be demolished and replaced by a new facility, scheduled to be complete in 2002. On April 6, 2000, the parties entered a stipulation for dismissal of the case, which the court (Judge Carol E. Jackson) approved. On May 24, 2000, the court granted the plaintiffs' motion for attorney fees and costs.Elizabeth Chilcoat - 06/27/2006