Case: Carver v. Knox County

3:86-cv-00299 | U.S. District Court for the Eastern District of Tennessee

Filed Date: April 25, 1986

Closed Date: 1990

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Case Summary

On April 25, 1986, a jail inmate filed a pro se lawsuit in the U.S. District Court for the Eastern District of Tennessee under 42 USC §1983 against Knox County and Tennessee officials regarding conditions at the Knox County Jail. A magistrate judge grated the inmate counsel and the case was eventually certified as a class action. Plaintiffs were represented by the University of Tennessee Legal Clinic. On January 25, 1989, the district court (Judge James H. Jarvis) found serious overcrowding at …

On April 25, 1986, a jail inmate filed a pro se lawsuit in the U.S. District Court for the Eastern District of Tennessee under 42 USC §1983 against Knox County and Tennessee officials regarding conditions at the Knox County Jail. A magistrate judge grated the inmate counsel and the case was eventually certified as a class action. Plaintiffs were represented by the University of Tennessee Legal Clinic. On January 25, 1989, the district court (Judge James H. Jarvis) found serious overcrowding at two of the three Knox County facilities. Carver v. Knox County, 753 F.Supp 1370 (E.D. Tenn. 1989). The court held that this overcrowding led to unconstitutional conditions and ordered the county and state to reduce the prison populations. The state defendants filed a motion for change of venue to consolidate this action with Grubbs v. Reynolds, a class action lawsuit concerning conditions within the state prison system, that was under the jurisdiction of the U.S. District Court for the Middle District of Tennessee. The motion was denied.

Judge Jarvis issued another opinion regarding the overcrowded conditions on March 17, 1989, after hearing further evidence from the parties. Carver v. Knox County, 753 F.Supp. 1394 (E.D. Tenn 1989). The court ordered the removal of more state prisoners from the jail. Judge Jarvis noted that the overcrowded conditions were a result of the 1985 order by Judge Thomas A. Higgins in the Grubbs litigation in the Middle District of Tennessee, which limited the number of inmates who could be accommodated within the Tennessee State Prison System, slowing down the movement of inmates from county to state facilities.

On appeal, the Sixth Circuit Court of Appeals (Judge Pierce Lively) noted that there were conflicting goals between this Carver case and the Grubbs litigation. Carver v. Knox County, 887 F.2d 1287 (6th Cir. 1989). The Sixth Circuit ordered the district court to sever the claims against the state defendants and transfer them to the Middle District of Tennessee. It also found that the district court's conclusion that all of the unconstitutional conditions at the Knox County facilities were a result of inmates from the state system was not supported by the evidence. The claims against the county defendants were remanded to the district court. The U.S. Supreme Court denied certiorari on April 30, 1990. Knox County v. McWherter, 495 U.S. 919 (1990)

On remand, Judge Jarvis adopted his previous opinions except as they discussed the cause of the unconstitutional conditions. Carver v. Knox County, 753 F.Supp. 1398 (E.D. Tenn. 1990). Judge Jarvis wrote that "the court concludes that it has already accomplished precisely what the Sixth Circuit now orders on remand."

 

Summary Authors

Kristen Sagar (6/13/2007)

Richard Jolly (11/4/2014)

Related Cases

Grubbs v. Bradley, Middle District of Tennessee (1980)

People


Judge(s)
Attorney for Plaintiff

Eldridge, John E. (Tennessee)

Attorney for Defendant

Beeler, Richard T. (Tennessee)

Burson, Charles W. (Tennessee)

Duffey, John (Tennessee)

Himmelreich, Davis (Tennessee)

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Documents in the Clearinghouse

Document

3:86-cv-00299

Order

Carver v. Knox County Tennessee

Jan. 25, 1989

Jan. 25, 1989

Order/Opinion

3:86-cv-00299

Memorandum Opinion

Carver v. Knox County Tennessee

March 17, 1989

March 17, 1989

Order/Opinion

89-05341

89-05369

Order

Carver v. Knox County Tennessee

U. S. Court of Appeals for the Sixth Circuit

Oct. 6, 1989

Oct. 6, 1989

Order/Opinion

3:86-cv-00299

Memorandum Opinion

Carver v. Knox County Tennessee

March 19, 1990

March 19, 1990

Order/Opinion

89-01440

Cert Denial

Knox County Tennessee v. McWherter

Supreme Court of the United States

April 30, 1990

April 30, 1990

Order/Opinion

Docket

Last updated Feb. 15, 2024, 3:28 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Tennessee

Case Type(s):

Jail Conditions

Key Dates

Filing Date: April 25, 1986

Closing Date: 1990

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

inmates of the Knox County Jail

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: Yes

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Knox County (Knox), County

Defendant Type(s):

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Available Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Declaratory Judgment

Source of Relief:

Litigation

Order Duration: 1989 - 0

Issues

General:

Bathing and hygiene

Food service / nutrition / hydration

Totality of conditions

Jails, Prisons, Detention Centers, and Other Institutions:

Library (non-law) access

Crowding / caseload

Medical/Mental Health:

Medical care, general

Type of Facility:

Government-run

Non-government non-profit