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Case Name Hines v. Anderson PC-MN-0002
Docket / Court 73-387 ( D. Minn. )
State/Territory Minnesota
Case Type(s) Prison Conditions
Case Summary
In August 1973, inmates at the Minnesota State Prison filed this class action lawsuit in the District of Minnesota against the Minnesota State Prison and all related officials. The plaintiffs, represented by private counsel, sued under 42 U.S.C. § 1983 and claimed that the medical care and ... read more >
In August 1973, inmates at the Minnesota State Prison filed this class action lawsuit in the District of Minnesota against the Minnesota State Prison and all related officials. The plaintiffs, represented by private counsel, sued under 42 U.S.C. § 1983 and claimed that the medical care and facilities at the Minnesota State Prison were inadequate, in violation of the Eighth and Fourteenth Amendments.

In May 1977, the District Court (Judge Earl R. Larson) accepted a consent agreement reached by the parties and entered a consent decree establishing guidelines for the provision of medical care and treatment for inmates in the Minnesota State Prison. The consent decree required that, with respect to the primary maximum security prison for men in Minnesota, the applicable state law (commonly known as the "Patients Bill of Rights") would apply to the fullest extent possible to inmates requiring medical treatment. The decree required that no inmate be deprived of medical care, medication, or prosthetic devices due to indigence. Additionally, the decree required that the prison have a full-time physician and medical staff on daily, weekend, and "on-call" duty. The Court retained jurisdiction for oversight of the consent decree's implementation. The District Court also granted class certification for a class of “all inmates of the Minnesota State Prison who are now or may in the future be in the need of medical care, including examination, diagnosis or treatment, while so confined.” 439 F. Supp. 12.

The decree was limited to the "primary maximum security prison for men in Minnesota.” Initially it applied to the Minnesota State Prison in Bayport, Minnesota, but from 1999 onward applied only to the Minnesota Correctional Facility at Oak Park Heights. Although the original paper docket for this case is unavailable, the available PACER docket indicates that from 1996 until 2002, several individual inmates made repeated motions for contempt, all of which were denied without prejudice by the District Court (Judge Michael J. Davis).

In August 2002, the defendants moved to terminate the consent decree under the Prison Litigation Reform Act pursuant to § 3626(b). The Prison Litigation Reform Act, enacted by Congress in 1996, outlined appropriate remedies in civil litigation regarding prison conditions. Section 3626(b) addressed the termination of relief and applied retroactively to prospective relief that was entered before the statute's enactment. Initially, the District Court denied the defendant's motion without prejudice, reasoning that the Court lacked subject matter jurisdiction over the motion. However, the Eighth Circuit Court of Appeals (Judges Roger L. Wollman, George G. Fagg, and Morris S. Arnold) reversed and remanded, finding that a case or controversy existed. 83 Fed. Appx. 148.

In November 2004, Magistrate Judge Arthur J. Boylan issued a report and recommendation that the district court grant the defendants’ motion to terminate the decree. After reviewing the plaintiffs’ objections, the District Court granted the plaintiffs leave to engage in additional discovery for the purpose of presenting evidence of ongoing Eighth Amendment violations at the Oak Park Heights Facility.

Following discovery, both parties submitted supplemental memorandums and exhibits with respect to the motion to terminate the decree. The plaintiffs filed a report prepared by their expert, and individual inmates filed numerous submissions regarding the alleged inadequacies of their medical care. In turn, the defendants submitted the medical records pertaining to those individuals. The matter was again submitted to Magistrate Judge Boylan for review, and in January 2007, he issued another report and recommendation. The report found that neither the plaintiffs’ declarations nor their expert submissions supported the plaintiffs’ argument that there were current and ongoing Eighth Amendment violations. The report further found that the decree was not narrowly constructed and that its provisions addressed issues that were ancillary to core Eighth Amendment medical treatment issues. The report concluded by recommending that the decree be terminated. After conducting a de novo review, the District Court adopted the report’s recommendation and denied the plaintiffs’ request for further discovery and an evidentiary hearing.

The plaintiffs appealed this decision, and on November 21, 2008, the Court of Appeals (Judges Roger L. Wollman, C. Arlen Beam, and Kermit E. Bye) affirmed the District Court decision. The Court found that neither the Due Process Clause nor the Prisoner Litigation Reform Act entitled the plaintiffs to further discovery or an evidentiary hearing because a consent decree is not a final judgment and thus the plaintiffs did not have a vested property interest in the decree. The Court also held that the plaintiffs had failed to show that the defendants’ failure to provide medical care to prisoners amounted to an Eighth Amendment violation. Finally, the Court upheld the District Court’s finding that the consent decree was not narrowly drawn. 547 F.3d 915. The case was closed in March 2007.

Kristen Sagar - 08/02/2007
Sara Stearns - 07/01/2019


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Defendant-type
Corrections
General
Conditions of confinement
Confidentiality
Counseling
Food service / nutrition / hydration
Staff (number, training, qualifications, wages)
Medical/Mental Health
Medical care, general
Medication, administration of
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Governor of State of Minnesota
Minnesota State Prison
Plaintiff Description Prisoners at the Minnesota State Prison
Class action status sought Yes
Class action status granted Yes
Filed Pro Se No
Prevailing Party Mixed
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1977 - 2007
Filing Year 1973
Case Closing Year 2007
Case Ongoing No
Additional Resources
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  Civil Rights Injunctions Over Time: A Case Study of Jail and Prison Court Orders
N.Y.U. Law Review
Date: May 2006
By: Margo Schlanger (Washington University Faculty)
Citation: 81 N.Y.U. L. Rev. 550 (2006)
[ Detail ] [ PDF ] [ External Link ]

  Judicial Policy Making and the Modern State: How the Courts Reformed America's Prisons
Book
Date: Jan. 1, 1998
By: Malcolm M. Feeley & Edward Rubin (UC Berkeley Boalt Hall School of Law & Vanderbilt School of Law Faculty Faculty)
Citation: (1998)
[ Detail ]

Docket(s)
73-387 (D. Minn.)
PC-MN-0002-9000.pdf | Detail
Date: 05/04/2012
Source: PACER [Public Access to Court Electronic Records]
General Documents
Order and Consent Decree (439 F.Supp. 12) (D. Minn.)
PC-MN-0002-0003.pdf | WESTLAW| LEXIS | Detail
Date: 05/27/1977
Source: Google Scholar
Opinion (83 Fed.Appx. 148)
PC-MN-0002-0004.pdf | WESTLAW| LEXIS | Detail
Date: 12/15/2003
Source: Google Scholar
Report and Recommendation on Motion to Terminate Consent Decree [ECF# 802] (D. Minn.)
PC-MN-0002-0001.pdf | Detail
Date: 01/29/2007
Source: PACER [Public Access to Court Electronic Records]
Order Terminating Consent Decree [ECF# 807] (D. Minn.)
PC-MN-0002-0002.pdf | Detail
Date: 03/30/2007
Source: PACER [Public Access to Court Electronic Records]
Opinion (547 F.3d 915)
PC-MN-0002-0005.pdf | WESTLAW| LEXIS | Detail
Date: 11/21/2008
Source: Westlaw
show all people docs
Judges Arnold, Richard Sheppard (E.D. Ark., W.D. Ark., Eighth Circuit) show/hide docs
PC-MN-0002-0004
Beam, Clarence Arlen (D. Neb., Eighth Circuit) show/hide docs
PC-MN-0002-0005
Boylan, Arthur J. (D. Minn.) show/hide docs
PC-MN-0002-0001 | PC-MN-0002-9000
Bye, Kermit Edward (Eighth Circuit) show/hide docs
PC-MN-0002-0005
Davis, Michael James (FISC, D. Minn.) show/hide docs
PC-MN-0002-9000
Fagg, George Gardner (Eighth Circuit) show/hide docs
PC-MN-0002-0004
Larson, Earl Richard (D. Minn.) show/hide docs
PC-MN-0002-0003
Schiltz, Patrick Joseph (D. Minn.) show/hide docs
PC-MN-0002-0002
Wollman, Roger Leland (Eighth Circuit) show/hide docs
PC-MN-0002-0004 | PC-MN-0002-0005
Plaintiff's Lawyers Cullen, James P. (Minnesota) show/hide docs
PC-MN-0002-0003 | PC-MN-0002-9000
Vasaly, Mary Ruth (Minnesota) show/hide docs
PC-MN-0002-9000
Defendant's Lawyers Jensen, Thomas H. (Minnesota) show/hide docs
PC-MN-0002-0003
Lockhart, Greer E. (Minnesota) show/hide docs
PC-MN-0002-0003
Service, Jennifer A. (Minnesota) show/hide docs
PC-MN-0002-0004 | PC-MN-0002-9000
Other Lawyers Nearing, Carolin J. (Minnesota) show/hide docs
PC-MN-0002-9000

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