Filed Date: Aug. 28, 1986
Closed Date: 1992
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On 08/28/1986, inmates of the Hocking Correctional Facility filed a Section 1983 suit, pro se, in the Southern District of Ohio against officials of the facility. Plaintiffs claimed violations of the Eighth Amendment, specifically alleging overcrowding, excessive noise, inadequate storage, inadequate heating and cooling, unclean lavatories, improper classification of prisoners, and unsanitary eating conditions. In 1991 the ACLU National Prison Project agreed to represent plaintiff.
The parties filed cross-motions for summary judgment and the district court found in favor of the defendants. Plaintiffs appealed and the Court of Appeals affirmed. The Sixth Circuit (Judge James Harvey) held that appellants' claims of constitutional violations did not arise from specific conditions previously found to violate the Eighth Amendment and that the appellants failed to establish that prison conditions were a product of ""obduracy and wantonness and not mere negligence."" Wilson v. Seiter, 893 F.2d 861 (6th Cir. 1990).
Plaintiffs' petition for writ of certiorari was granted. Wilson v. Seiter, 498 U.S. 808 (1990). The Supreme Court vacated and remanded. Writing for the majority, Justice Scalia held that Eighth Amendment prison claims require an objective and subjective component. Plaintiffs must show that the conditions are objectively cruel and unusual and that they are the result of ""deliberate indifference"" by prison officials. The majority also held that the courts should not question the constitutionality of all conditions in their ""totality"" unless they ""have a mutually enforcing effect that produces the deprivation of a single, identifiable human need."" Wilson v. Seiter, 501 U.S. 294 (1991).
After reconsideration applying the ""deliberate indifference"" standard, the District Court (Judge James L. Graham) granted defendants' motion for summary judgment and dismissed the case in a March 1992 opinion and order. Plaintiffs appealed, but the Court of Appeals affirmed.
Summary Authors
Eoghan Keenan (7/15/2005)
Abel, Mark R. (Ohio)
Blackmun, Harry Andrew (District of Columbia)
Alexander, Elizabeth R. (District of Columbia)
Chesley, Stanley Morris (Ohio)
Bryson, William Curtis (District of Columbia)
Abel, Mark R. (Ohio)
Blackmun, Harry Andrew (District of Columbia)
Graham, James L. (Ohio)
Harvey, James (Michigan)
Kennedy, Anthony McLeod (District of Columbia)
Krupansky, Robert B. (Ohio)
Marshall, Thurgood (District of Columbia)
O'Connor, Sandra Day (District of Columbia)
Rehnquist, William Hubbs (District of Columbia)
Scalia, Antonin (District of Columbia)
Souter, David Hackett (District of Columbia)
Stevens, John Paul (District of Columbia)
Wellford, Harry Walker (Tennessee)
White, Byron Raymond (District of Columbia)
Last updated Jan. 27, 2024, 3:08 a.m.
State / Territory: Ohio
Case Type(s):
Key Dates
Filing Date: Aug. 28, 1986
Closing Date: 1992
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Inmates alleging cruel and unusual punishments
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: Yes
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Hocking Correctional Facility (Nelsonville), State
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
U.S. Supreme Court merits opinion
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Source of Relief:
Order Duration: 1992 - None
Issues
General:
Food service / nutrition / hydration
Sanitation / living conditions
Jails, Prisons, Detention Centers, and Other Institutions:
Type of Facility: