Present and future general prison population inmates at the Iowa State Penitentiary in Fort Madison, Iowa, filed a class action lawsuit on April 17, 1978 under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Iowa, alleging that the totality of conditions of confinement violated the Eighth and Fourteenth Amendments. The plaintiffs were represented by legal interns at the University of Iowa College of Law Legal Clinic. Americans United for Separation of Church and State represented one of the plaintiff class representatives. After a three-week trial, the District Court (Judge William C. Stuart) found that a proposed settlement would rectify the unconstitutional conditions of confinement. Watson v. Ray, 90 F.R.D. 143 (S.D.Iowa 1981). The decree required annual monitoring of the Iowa State Penitentiary.

Upon the enactment of the Prison Litigation Reform Act of 1995 (PLRA), the defendants moved to terminate the consent decree on May 10, 1996. The District Court (Judge Charles R. Wolle) denied this motion on February 10, 1997. Watson v. Ray, No. 4-78-CV-80106, 1997 WL 675579 (S.D.Iowa Feb. 10, 1997). However, the Court of Appeals for the Eighth Circuit reversed his decision in light of Gavin v. Branstad, 122 F.3d 1081 (8th Cir. 1997). On remand, the District Court on August 10, 1998 terminated the decree, concluding that the PLRA was constitutional. On appeal and on September 29, 1999, the U.S. Court of Appeals for the Eighth Circuit (Judge John F. Nangle, sitting by designation) affirmed the termination of the consent decree. Watson v. Ray, 192 F.3d 1153 (8th Cir. 1999). This decision terminated the case.

David Terry - 04/25/2006


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