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Case Name Hamilton v. Vannoy PC-LA-0017
Docket / Court 3:17-cv-00194-SDD-RLB ( M.D. La. )
State/Territory Louisiana
Case Type(s) Prison Conditions
Case Summary
On March 29, 2017, plaintiffs, individuals held in prolonged solitary confinement on death row at Louisiana State Penitentiary (Angola) filed this class action lawsuit in the U.S. District Court for the Middle District of Louisiana. The plaintiffs sued the warden of Angola under 42 U.S.C. § 1983 ... read more >
On March 29, 2017, plaintiffs, individuals held in prolonged solitary confinement on death row at Louisiana State Penitentiary (Angola) filed this class action lawsuit in the U.S. District Court for the Middle District of Louisiana. The plaintiffs sued the warden of Angola under 42 U.S.C. § 1983. They claimed that placing prisoners in solitary confinement merely because they had been sentenced to death violated their Eighth Amendment right against cruel and unusual punishment and their Fourteenth Amendment due process rights. The plaintiffs, represented by the Cardozo Civil Rights Clinic, sought declaratory and injunctive relief as well as monetary relief and attorneys’ fees and costs. This case was assigned to Judge Shelly D. Dick.

The plaintiffs noted in the complaint that anyone sentenced to death was automatically confined to solitary confinement on death row upon their arrival at Angola. The placement in solitary confinement was not based on violation of prison rules, behavioral considerations, or anything other than their death sentence. Over 75 percent of the 70 prisoners had been in solitary confinement for over a decade. The complaint also alleged that the plaintiffs were confined to windowless cells the size of an average home bathroom for 23 hours per day. In contrast to other prisoners at Angola, those on death row were denied any opportunity to challenge their placement in solitary confinement through any administrative means, nor were they given periodic reviews to determine whether they needed to remain in solitary confinement.

In the complaint, the injunctive relief sought included permanently enjoining the defendants from violating the Eighth and Fourteenth Amendment rights of prisoners. The plaintiff also asked the court to grant a permanent injunction requiring the defendants to present a plan to the Court within 30 days that provided for the release from solitary confinement of the death row prisoners.

On December 15, 2017, the plaintiffs filed a motion to certify two classes. The first, a due process class, included “[a]ll current and future Death Row prisoners at Louisiana State Penitentiary in Angola, Louisiana, as well as other prisoners sentenced to death at Angola who are similarly situated.” The second, an Eighth Amendment class, included “[a]ll current and future Death Row prisoners who are now, or will be, on Death Row under the conditions described above for more than five continuous years.”

In August 2018, the parties began settlement negotiations. As part of the negotiations, the plaintiffs withdrew their motion for class certification under the condition that it would be reinstated if negotiations were unsuccessful. Their motion to withdraw was granted by Judge Dick on September 8, 2018. The parties continued to negotiate for settlement (unsuccessfully) through the rest of 2018 and all of 2019. On January 6, 2020, the court informed the parties that further efforts to facilitate settlement by the court would not continue, and that the parties should anticipate going to trial if they could not reach an agreement.

Finally, in 2021, the parties were able to reach a settlement. They jointly filed a motion for class certification in July 2021 and shortly thereafter submitted a proposed settlement. On September 28, 2021, Judge Dick certified the class and approved the settlement agreement. The certified class consisted of "all current and future men sentenced to death and in the custody of the LDOC." The parties agreed that each class members would receive at least four hours of congregate out-of-cell time every day. During this time, individuals could congregate with other class members, shower, use the phone, or use a JPay machine. The settlement agreement also provided that individuals would be given at least five hours of congregate recreation time in the yard per week. Additional provisions provided opportunities for religious worship, education, work opportunities, contact and non-contact visits, and communal lunches. The court retained jurisdiction to enforce the agreement, and the defendants agreed that the case would not terminate until they "substantially complied" with the agreement for at least four years.

The case is ongoing.

Jake Parker - 05/24/2018
Alex Moody - 05/26/2020
Justin Hill - 10/03/2021


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Due Process: Procedural Due Process
Due Process: Substantive Due Process
Defendant-type
Corrections
General
Administrative segregation
Classification / placement
Conditions of confinement
Disciplinary procedures
Disciplinary segregation
Recreation / Exercise
Religious programs / policies
Solitary confinement/Supermax (conditions or process)
Totality of conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Secretary of the Louisiana Department of Public Safety Corrections
Warden of Angola
Warden of Death Row
Plaintiff Description All current and future men sentenced to death and in the custody of the LDOC.
Class action status sought Yes
Class action status outcome Granted
Filed Pro Se No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Filed 03/29/2017
Case Ongoing Yes
Additional Resources
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  See this case at CourtListener.com (May provide additional documents and, for active cases, real-time alerts)
Court Docket(s)
M.D. La.
09/28/2021
3:17-cv-00194-SDD-RLB
PC-LA-0017-9000.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
General Documents
M.D. La.
03/29/2017
Class Action Complaint and Demand For Jury Trial [ECF# 1]
PC-LA-0017-0001.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
M.D. La.
09/28/2021
Order [ECF# 110]
PC-LA-0017-0002.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
show all people docs
Judges Bourgeois, Richard L. (M.D. La.) [Magistrate] show/hide docs
PC-LA-0017-9000
Dick, Shelly Deckert (M.D. La.) show/hide docs
PC-LA-0017-0002 | PC-LA-0017-9000
Plaintiff's Lawyers Ginsberg, Betsy R. (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Malhotra, Garima (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Menon, Lekha show/hide docs
PC-LA-0017-0001
Muir, Robin L. (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Rhermoul, Hasnaa El show/hide docs
PC-LA-0017-0001
Schiavo, Nicole E. (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Seaver, Elizabeth A. (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Trenticosta, Nicholas J. (Louisiana) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Van Tol, Pieter (New York) show/hide docs
PC-LA-0017-0001 | PC-LA-0017-9000
Defendant's Lawyers Blanchfield, Andrew (Louisiana) show/hide docs
PC-LA-0017-9000
Jones, Christopher K. (Louisiana) show/hide docs
PC-LA-0017-9000
LeBlanc, Crews Reynolds Jr. (Louisiana) show/hide docs
PC-LA-0017-9000
Payne, Chelsea Acosta (Louisiana) show/hide docs
PC-LA-0017-9000
Other Lawyers Nordyke, Keith B (Louisiana) show/hide docs
PC-LA-0017-9000

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