On October 7, 1975, post-trial detainees at the District of Columbia jail brought a class action lawsuit under 42 U.S.C. §1983 in the United States District Court for the District of Columbia alleging that various conditions at the jail were unconstitutional. The plaintiff class was represented by the National Prison Project of the American Civil Liberties Union. On May 24, 1976, the District Court (Judge William Benson Bryant) granted the plaintiffs' motion for partial summary judgment by holding that the conditions and practices at the jail constituted cruel and unusual punishment. Inmates, D.C. Jail v. Jackson, 416 F.Supp. 119 (D.D.C. 1976). The jail was found to be overcrowded, without proper care for inmates with psychiatric problems, lacking in recreation opportunities, having overly restrictive visitation rights along with generally unsafe and unsanitary conditions. Judge Bryant also ordered the defendant jail officials to initiate action to correct these violations. Judge Bryant extended many of the District Court's findings from Campbell v. McGruder (JC-DC-001) which involved unconstitutional jail conditions for pre-trial detainees. The cases were, in fact, consolidated for some time, and therefore many of the relevant documents appear in both case files.
Judge Bryant issued subsequent orders in July and August 1985, and the parties reached a stipulated agreement on August 22, 1985 to reduce the jail population. On March 11, 1987, Judge Bryant held the jail officials in civil contempt for violating provisions in those orders regarding Halfway House capacity, inmate classification and reductions in minimum sentences. Inmates of D.C. Jail v. Jackson, No. 1462-71, 1987 WL 8724 (D.D.C. Mar. 11, 1987). Judge Bryant imposed fines on the jail officials and ordered them to file bi-weekly compliance reports with the Court.
The District continued to find a pattern of constitutional violations and repeatedly issued orders to bring conditions at the D.C. jail into compliance. The D.C. jail was so recalcitrant in complying with the court-ordered reforms that Judge Bryant was prompted to state that the jail's lack of compliance bordered on bad faith. Transcript, Nov. 1, 1994 Hearing, Inmates of the D.C. Jail v. Jackson (No. 75-1668).
The docket for the case is available on PACER for all entries in the case after May 12, 1989. The docket mentions a Special Master, Grace Lopes, who was assigned to monitor the implementation of the District Court's orders. On November 6, 1997, Karen Schneider replaced Grace Lopes as the Special Master assigned to the case.
After passage of the Prison Litigation Reform Act (PLRA), Judge Bryant awarded attorneys' fees at market rates to attorneys monitoring compliance with the District Court's orders, finding the PLRA inapplicable. The United States Court of Appeals for the District of Columbia Circuit (Judge David Bryan Sentelle) reversed by holding that the PLRA's cap on attorney fee awards is applicable to all work performed after its effective date. Inmates of D.C. Jail v. Jackson, 158 F.3d 1357 (D.C. Cir. 1998). Judge Patricia McGowan Wald dissented by arguing that the PLRA's limitations on attorneys' fees was being applied retroactively because the case began before passage of the PLRA. On June 24, 1999, the U.S. Supreme Court denied certiorari. Inmates of D.C. Jail v. Edwards, 527 U.S. 1035 (1999).
On June 13, 2002, Judge Bryant stayed the population limitation imposed by court order. The case was dismissed on March 21, 2003, although some litigation continued after that date regarding attorneys' fees.
Tom Madison - 04/02/2006
compress summary
