In 1975, two inmates at the Southern Ohio Correctional Facility filed a lawsuit, pro se, under 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Ohio against officials of the Ohio State Prison system. Certification as a class action was originally denied on the ground that the asserted representatives were not qualified to represent the claimed class. After the American Civil Liberties Union entered appearances on behalf of the plaintiffs, the case was certified as a class action. Plaintiffs alleged that defendants' practice of double celling, whereby two inmates were housed in a single cell, constituted cruel and unusual punishment in violation of the Eighth Amendment.

On June 29, 1977, the District Court (Chief Judge Timothy Sylvester Hogan) held that although housing two inmates in one cell was not unconstitutional per se, the limited amount of square-footage provided to prisoners at Southern Ohio Correctional Facility rendered double-celling under the circumstances unconstitutional. Chapman v. Rhodes, 434 F. Supp. 1007 (S.D. Ohio 1977). Judge Hogan ordered defendants to produce a plan within 90 days that would terminate double celling at Southern Ohio Correctional Facility. Defendants appealed and on June 6, 1980, the Sixth Circuit affirmed without opinion. Chapman v. Rhodes, 624 F.2d 1099 (6th Cir. 1980). The Supreme Court granted certiorari and the plaintiffs' motions to proceed in forma pauperis. Rhodes v. Chapman, 449 U.S. 951 (1980).

The Supreme Court (Justice Lewis Franklin Powell) reversed. Rhodes v. Chapman, 452 U.S. 337 (1981). Writing for the majority, Justice Powell held that double celling at the prison did not violate the Eighth Amendment, noting that despite the fact that prisoners were serving long sentences, that double-celling wasn't temporary, that the prison was over capacity, and that prisoners spent much time in the cells with their cellmates, the conditions of double-celling were nevertheless insufficient to constitute cruel and unusual punishment. Justices Brennan and Blackmun filed concurring opinions, and Justice Marshall filed a dissenting opinion in the case.

Eoghan Keenan - 06/10/2005


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