On September 8, 1970, five pretrial detainees filed a lawsuit in the U.S. District Court for the Northern District of California under 42 U.S.C. § 1983, on behalf of themselves and all others awaiting trial in the Greystone section of the Santa Rita Rehabilitation Center in California. The named defendants were the Sheriff and the members of the Board of Supervisors of Alameda County where the facility was located. The plaintiffs claimed that conditions at the facility were cruel and unusual punishment in violation of their 14th Amendment rights. After the judge visited the facility, on March 11, 1971, the court instructed the defendants to take whatever steps necessary to alleviate the cruel and unusual conditions of confinement at Greystone. The defendants made regular reports to the court regarding their progress over the next year.

On May 12, 1972, the U.S. District Court for the Northern District of California (Judge Alfonso Zirpoli) ruled that the conditions of confinement at Greystone violated the Due Process and Equal Protection rights of pretrial detainees. Brenneman v. Madigan, 343 F.Supp. 128 (N.D. Cal. 1972). The court found that the proper analysis for pretrial detainees was under the 14th Amendment rather than the 8th Amendment because they had not yet been found guilty of any crime. The court stated that the only valid interest the state possessed in restricting the liberty of the pretrial detainees was in ensuring their presence in court. The court found that administrative costs and expedience were not compelling reasons for violating the plaintiffs rights. The court ordered that the defendants not hold pretrial detainees continuously in cells, that the defendants offer activities for the pretrial detainees, that the pretrial detainees have access to phones for a large amount of time and that the pretrial detainees be allowed to visit as may people as they wish for more than 15 minutes per week. The parties were ordered to keep reporting to the court regarding their progress and the defendants were ordered to file a proposed set of rules for the treatment of pretrial detainees with the court within 90 days.

Jaclyn Adams - 02/20/2006


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