On November 21, 1975, four inmates confined at the Indiana Reformatory in Pendleton, Indiana filed a pro se lawsuit pursuant to 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Indiana, challenging their conditions of confinement. The initial pro se complaint was dismissed by the Court with leave granted to re-file the case. On May 13, 1976, attorneys for the Legal Services Organization of Indianapolis, Indiana filed an amended class action complaint, alleging poor living conditions, inadequate medical care, lack of safety and security, bad food services, inadequate educational opportunities, insufficient access to the courts, and an arbitrary system of prison discipline at the Reformatory. The case was certified as a class action on December 20, 1977.
The U.S. Department of Justice (DOJ) was granted leave to participate as amicus curiae on March 10, 1978.
Trial began on July 5, 1978 and ended on August 14, 1978. It was reopened for further proceedings between March 1-5, 1982. The District Court (Judge S. Hugh Dillin) found for the plaintiff class and ordered changes to the operation of the Reformatory in the areas of: inmate population, medical care, food, sanitation, recreational opportunities, security, mental health programs, and fire safety. French v. Owens, 538 F.Supp. 910 (S.D. Ind. 1982). Defendants appealed.
The Court of Appeals for the Seventh Circuit remanded to determine whether the injunctive relief ordered by the District Court was based on state law or the Eighth Amendment, in light of the recent Supreme Court decision Pennhurst State School and Hospital v. Haldemzan, 465 US. 89, 104 S.Ct. 900, 79 L.Ed.2d 67 (1984), which held that federal courts lacked jurisdiction over claims for injunctive relief against state officials based upon state law.
On remand, the District Court found that most of the Reformatory conditions violated the Eighth Amendment as well as state law. The Court issued an amended order in light of the Pennhurst case. The amended order also accounted for improvements that had been made at the Reformatory since the Court's original order. The defendants appealed again.
The Court of Appeals (Judge Richard Dickson Cudahy) affirmed in part, holding that conditions in the state prison such as overcrowding, double celling, unwholesome food, medical neglect, and threats to inmates' safety violated the Eighth Amendment. The Court of Appeals also vacated and remanded the judgment as it pertained to exercise, protective custody, and fire and occupational safety. French v. Owens, 777 F.2d 1250 (7th Cir. 1986).
In 1998, the defendants petitioned to terminate the injunction pursuant to the Prison Litigation Reform Act [PLRA]. The District Court (Judge S. Hugh Dillin) granted a preliminary injunction against the enforcement of the PLRA's automatic stay provision. The defendants appealed. The Court of Appeals (Judge Diane P. Wood) affirmed, holding that the automatic stay provision of the PLRA, codified at 18 U.S.C. § 3626(e)(2), was unconstitutional. French v. Duckworth, 178 F.3d 437 (7th Cir. 1999).
The Supreme Court of the United States granted certiorari and reversed and remanded, holding that the automatic stay provision of the PLRA did not violate separation of powers principles. Miller v. French 530 U.S. 327 (2000).
Following remand, the District Court's Decree Order was terminated on October 23, 2000 pursuant to the PLRA. According to information received from the state AGs office, upon its termination, the parties entered into a Private Settlement Agreement as to the continued operation of the Reformatory, which had been renamed as the Pendleton Correctional Facility. The Agreement expired by its own terms on October 23, 2002. No subsequent decrees or agreements were entered and the case remained closed as of the date of this summary.
Note that there was no PACER docket available for this case.Rebekah Henn Sullivan - 03/06/2007