On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were ...
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On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were in violation of a consent decree issued in an earlier case, Pugh v. Locke, 406 F. Supp. 318 (M.D. Ala. 1976) (PC-AL-010), which mandated that there "shall be space available for inmates to engage in hobbies." Pugh, 406 F. Supp. at 335. The inmates were granted leave to proceed in forma pauperis, and each inmate represented himself pro se.
The inmates alleged that the "spirit and intent of the consent decree" was being violated in several ways by defendants. For example, the inmates alleged that defendants limited the amount of supplies inmates could order each month, limited the amount of finished crafts that inmates could mail out of the facility and to whom inmates could mail such crafts, limited the number of inmates who were allowed access to the hobby shop in a selective and discriminatory manner, and often closed the shop for up to two weeks as group punishment for incidents unrelated to the hobby shop. Restricted access to the hobby shop, according to the inmates, was a violation of the Eight Amendment because it restricted the inmates' means to make an income, and because the hobby shop was essential in order to maintain a safe environment in the overcrowded prison.
The U.S. District Court for the Southern District of Alabama found that the inmates had not made a successful claim, because they could not show that they had been deprived of a constitutional right. Specifically, the court found that: 1) there existed no constitutionally protected right for an inmate to have access to a hobby shop; 2) the claim that the denied access was in violation of the Pugh consent decree was not a violation of a federal right because the consent decree was no longer in effect following Newman v. Alabama, No. 3501-N, 1988 U.S. Dist. LEXIS 18633, (M.D. Ala. Dec. 28, 1998)(PC-AL-017) and because access to a hobby shop was not a constitutionally protected liberty interest and 3) denied or restricted access to a hobby shop is not a deprivation of a single human need, and therefore is not an Eight Amendment violation. The case was dismissed without prejudice as frivolous, prior to service of process (Judge Richard W. Vollmer, Jr. signed the Report and Recommendations issued by Mag. Judge William H. Steele on May 13, 1996). Crowe v. Jones, 96-0214, 1996 U.S. Dist. LEXIS 8566 (S.D. Ala. May 13, 1996).Megan Raynor - 01/23/2006