In September 1972, inmates of the Georgia State Prison (GSP) in Reidsville, Georgia, filed a class action lawsuit against GSP officials in the United States District Court for the Southern District of Georgia. The plaintiffs, represented by private counsel, filed an amended complaint in 1973, in which they alleged that the prison racially segregated inmates and engaged in unconstitutional practices. Following a court order, GSP was desegregated in 1974.
The remaining issues raised in the complaint were tried before a Special Master in July 1976. Specifically, the Special Master heard complaints about (1) the adequacy of medical and psychiatric care, (2) substandard environmental conditions, (3) unconstitutional disciplinary practices, (4) guard brutality, (5) racial discrimination in work assignments and discipline, (6) verbal abuse, (7) infringements on the rights of Muslim inmates, (8) law library deficiencies, (9) the lack of education and vocational activities, and (10) interference with the mail.
In 1978, the parties negotiated and signed three consent decrees to resolve these issues. The consent decrees, signed July 19, August 4, and December 1, represented attempts to arrive at a comprehensive settlement agreement. The three consent decrees, however, failed to resolve problems with medical care, mental health services, and racially discriminatory discipline.
The United States District Court for the Southern District of Georgia appointed a Special Monitor to survey compliance with the consent decrees. On November 27, 1979, the Special Monitor reported widespread non-compliance with the consent decree. Specifically, the Special Monitor found that GSP was not giving inmates notice of charges against them, allowing them to call witnesses in a disciplinary hearing, and disciplining them too often with unmonitored bread and water diets that did not include vitamin supplements. In addition, the Special Monitor found problems with the plumbing and sewage systems and fire safety. The court granted the plaintiffs immediate relief on January 7, 1980. On February 11, 1980, the court permanently enjoined the defendants from using bread and water diets and again ordered the State to comply with the consent decrees and previous court orders.
In April of 1981, GSP implemented a new disciplinary system. The plaintiffs filed a motion alleging continuing violations of the court's previous orders, including the defendants' use of forfeiture of earned time as a disciplinary sanction. Following settlement talks, GSP agreed to expunge disciplinary convictions entered between August 4, 1978, and April 20, 1981, from inmates' records. In addition, forfeited earned time was credited to inmates and the disciplinary charge was either retried or dropped based on an inmate classification system (non-serious offenders, serious offenders who pled not guilty, or serious offenders who pled guilty). On December 31, 1980, the District Court (Chief Judge Anthony A. Alaimo) held the agreement was a full, fair and adequate settlement and overruled all objections to the settlement. Guthrie v. Evans, 93 F.R.D. 390 (S.D. Ga. 1981).
In 1985, an individual class member filed a pro se appeal in the Court of Appeals for the Eleventh Circuit. On April 24, 1987, the United States Court of Appeals for the Eleventh District (Chief Judge Paul H. Roney) held that an unnamed class member could not appeal the final judgment of the district court. Guthrie v. Evans, 815 F.2d 626 (11th Cir. 1987). The appellate court also held that an unnamed class member was not entitled to object to court orders, although such a person could contest a proposed consent decree.
Elizabeth Chilcoat - 06/01/2006
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