Filed Date: Aug. 15, 1973
Closed Date: Feb. 13, 1997
Clearinghouse coding complete
In 1973, prisoners confined in administrative segregation in four California state prisons - San Quentin, Folsom, Dueul Vocational Institute at Tracy, and the Correctional Training Facility at Soledad - filed a class-action lawsuit under 42 U.S.C. §1983 against the California Department of Corrections in the U.S. District Court for the Northern District of California. The plaintiffs sought relief on two claims: 1) that they had been placed in administrative segregation without any procedural examination of whether they should be there, and 2) that they had been subjected to cruel and unusual punishment due to the poor conditions in which they were confined.
The administrative segregation claim was tried in a separate case called Wright v. Enomoto. In that lawsuit, a three-judge panel granted relief, finding that the plaintiffs' rights had been violated by a lack of due process when they were placed into administrative segregation. Wright v. Enomoto, 462 F.Supp. 397 (N.D.Cal. 1976). The defendants appealed this finding, and the Supreme Court affirmed it two years later. Wright v. Enomoto, 434 U.S. 1052 (1978).
This case involved the second claim for relief, in which the plaintiffs argued that their constitutional rights had been violated by poor conditions of confinement, including physical conditions, sanitation, food services, educational practices, medical services, placement and retention procedures, and the psychological impact of confinement in administrative segregation. On November 3, 1980, the District Court (Judge Stanley A. Weigel) granted a preliminary injunction to the plaintiffs, finding that the totality of conditions at Deuel, San Quentin, and Soledad were unconstitutional. The Court did not find that any specific part of the prison was unconstitutional, but the Court felt that the conditions as a whole were not good enough. The defendants appealed. On March 13, 1981, the U.S. Court of Appeals for the Ninth Circuit (Judge Joseph Tyree Sneed III) vacated the preliminary injunction and remanded the case for reconsideration. The Court found that the District Court had erred in its use of the "totality of conditions" approach, finding that only specific unconstitutional conditions may be remedied by the Eighth Amendment. The Ninth Circuit chided the District Court for trying to institute a prison reform program on its own under the guise of correcting cruel and unusual punishment. Wright v. Rushen, 642 F.2d 1129 (9th Cir. 1981).
On remand two years later, the District Court (Judge Weigel) re-issued the preliminary injunction, finding that specific conditions of confinement, including double-celling in small, window-less cells, inadequate lighting, heating, ventilation and plumbing, poor sanitation, inadequate food service, and inadequate medical care, were unconstitutional because they violated the Eighth Amendment prohibition on cruel and unusual punishment. Toussaint v. Rushen, 553 F.Supp. 1366 (N.D.Cal. 1983).
The defendants appealed, and on January 5, 1984, the Ninth Circuit (Judge William Cameron Canby, Jr.) partially affirmed and partially vacated the District Court's issuance of the preliminary injunction, finding that the District Court's finding that double-celling engendered violence, tension, and psychiatric problems, as well as the finding that physical conditions of the cells were inadequate, were valid. The Ninth Circuit vacated the portion of the injunction specifying the types and quantities of food that the inmates must be provided was invalid and must be overturned. Toussaint v. Yockey, 722 F.2d 1490 (9th Cir. 1984).
On October 18, 1984, following a trial on the merits, the District Court held that the conditions of confinement were unconstitutional with respect to double-celling, heating, ventilation, lighting, noise, plumbing, food preparation and storage, access to courts, clothing, laundry, and bedding. Toussaint v. McCarthy, 597 F.Supp. 1388 (N.D.Cal. 1984). The defendants appealed.
On September 30, 1986, the Ninth Circuit (Judge Robert R. Beezer) partially affirmed and partially vacated the District Court's opinion, remanding it for reconsideration. Specifically, the Ninth Circuit held that 1) due process required only that prison officials hold an informal nonadversary hearing within a reasonable time after the prisoner is placed in segregation, inform him of the charges against him, and give him an opportunity to present his views, 2) that it was error for the District Court to substitute its views for those of the prison administrator in determining when a prisoner should be released, 3) that review of segregation should be conducted more frequently than annually, 4) that the decision to place a prisoner in segregated confinement must be supported by some evidence, 5) that complaints about medical care did not rise to the level of an Eighth Amendment violation, and 6) that the denial of contact visits and work programs did not violate the Eighth Amendment. Toussaint v. McCarthy 801 F.2d 1080 (9th Cir. 1986). The parties sought Supreme Court review, and on May 26, 1987, the U.S. Supreme Court denied the petition for writ of certiorari. McCarthy v. Toussaint, 481 U.S. 1069 (1987).
On remand on April 20, 1989, the District Court (Judge Weigel) held that the review of indeterminate segregation decisions was required to occur every 90 days, that the defendants must undergo special procedures before placing inmates in indeterminate segregation, and that the defendants could not rely on polygraph examinations regarding gang affiliations as the basis for assigning prisoners to segregation. Toussaint v. Rowland, 711 F.Supp. 536 (N.D.Cal. 1989).
Both parties appealed, and on October 30, 1990, the Ninth Circuit (Judge John T. Noonan, Jr.) partially affirmed and partially reversed, holding that the continued appointment of a monitor to review decisions to assign inmates to segregation for administrative reasons was unwarranted. Toussaint v. McCarthy, 926 F.2d 800 (9th Cir. 1990). The parties sought Supreme Court review, and on October 7, 1991, the U.S. Supreme Court denied the petition for writ of certiorari. Toussaint v. McCarthy, 502 U.S. 874 (1991).
On June 29, 1992, the District Court (Stanley Weigel) entered a judgment that noted that the case was being "dismissed," but apparently continuing post-judgment monitoring. (We have only the docket sheet, not the order itself.) The state appealed this and other orders relating to fees, but the parties then agreed to dismissal of those appeals in July 1994. In January 1997, the parties jointly applied to vacate the injunctions and finally dismiss the case. The Court agreed, dismissing the case with prejudice on Feb. 13, 1997.
Summary Authors
Kristen Sagar (10/8/2007)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/9455925/parties/wright-v-enomoto/
Beezer, Robert R. (Washington)
Arriola, Anita P. (California)
Asaro, Andrea G. (California)
Baller, Morris J. (California)
Bergesen, B. E. III (California)
Beezer, Robert R. (Washington)
Brazil, Wayne D. (California)
Canby, William Cameron Jr. (Arizona)
Chambers, Richard Harvey (Arizona)
Kennedy, Anthony McLeod (District of Columbia)
Kozinski, Alex (California)
Noonan, John T. Jr. (California)
Rea, William J. (California)
Schroeder, Mary Murphy (Arizona)
Sneed, Joseph Tyree III (California)
Weigel, Stanley Alexander (California)
Wiggins, Charles Edward (California)
Wright, Eugene Allen (Washington)
Arriola, Anita P. (California)
Baller, Morris J. (California)
Bergesen, B. E. III (California)
Comiskey, Paul Wayne (California)
Fiering, Susan S. (California)
Flanagan, Sarah G. (California)
Goldblatt, Ellen Sue (California)
Hulett, Denise M. (California)
Jones, Constance M. (California)
Littlefield, Margaret (California)
Martinez, Vilma S. (California)
Miller, Samuel R. (California)
Phillips, Barbara Y. (California)
Reynolds, Gary P. (California)
Rosen, Sanford Jay (California)
Satris, Michael H. (California)
Specter, Donald H. (California)
Sturdevant, James C. (California)
Turner, William Bennett (California)
Buzzell, C. Michael (California)
Lungren, Daniel E. (California)
OReilley, Michael D. (California)
Prahl, William G. (California)
Prince, George D. (California)
Rivlin, Catherine A. (California)
Siggins, Peter J. (California)
Slavin, Bruce Michael (California)
Stein, William D. (California)
Van de Kamp, John K. (California)
See docket on RECAP: https://www.courtlistener.com/docket/9455925/wright-v-enomoto/
Last updated Feb. 7, 2024, 3:13 a.m.
State / Territory: California
Case Type(s):
Special Collection(s):
California's Prisoners' Rights Bar article
Key Dates
Filing Date: Aug. 15, 1973
Closing Date: Feb. 13, 1997
Case Ongoing: No
Plaintiffs
Plaintiff Description:
prisoners confined in administrative segregation in four California state prisons – San Quentin, Folsom, Dueul Vocational Institute at Tracy, and the Correctional Training Facility at Soledad
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: Unknown
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
California Department of Corrections, State
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Order Duration: 1976 - 1997
Content of Injunction:
Issues
General:
Food service / nutrition / hydration
Sanitation / living conditions
Jails, Prisons, Detention Centers, and Other Institutions:
Solitary confinement/Supermax (conditions or process)
Affected Sex or Gender:
Medical/Mental Health:
Type of Facility: