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Civil Rights Litigation Clearinghouse
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Case Name Grubbs v. Bradley PC-TN-0007
Docket / Court 3:80-cv-03404 ( M.D. Tenn. )
State/Territory Tennessee
Case Type(s) Prison Conditions
Attorney Organization ACLU National Prison Project
Legal Services/Legal Aid
Case Summary
On August 11, 1980, several inmates filed pro se complaints in the United States District Court for the Middle District of Tennessee under 42 U.S.C. § 1983 against the Tennessee Attorney General. The cases were consolidated despite abstention issues and in light of the 6th Circuit's ... read more >
On August 11, 1980, several inmates filed pro se complaints in the United States District Court for the Middle District of Tennessee under 42 U.S.C. § 1983 against the Tennessee Attorney General. The cases were consolidated despite abstention issues and in light of the 6th Circuit's decision Hanna v. Toner. Attorneys were appointed to represent plaintiffs, including Legal Services of Middle Tennessee, Legal Services of South Central Tennessee, National Prison Project of the American Civil Liberties Union, Rural Legal Services of Tennessee, and Legal Aid in Nashville. The plaintiff prisoners alleged that the conditions of confinement and practices in Tennessee's adult penal institutions amounted to cruel and unusual punishment in violation of the Eighth Amendment, applied to the states through the Fourteenth Amendment, as well as the state's constitution. The amended complaint also resulted in certification of the plaintiffs as a class of all present and future adult male inmates committed to the Tennessee Department of Correction.

The complaint challenged living conditions in Tennessee's prisons, ranging from overcrowding and sanitation to medical care and violence. Such "wanton infliction of unnecessary pain and suffering," the plaintiffs alleged, amounted to cruel and unusual punishment.

In August of 1982, the district court (Judge Leland Clure Morton) found that the conditions within Tennessee's adult penal institutions were unconstitutional under the Eighth Amendment and ordered the defendants to establish remedies and submit them to the court. Grubbs v. Bradley, 552 F.Supp. 1052 (M.D.Tenn. 1982). The court found specific facilities--but not all in the system--were inadequate to accommodate a growing prison population, and mandated that the prisons cease double celling in those units. While the court noted significant concern with prison conditions, including serious fire hazards and sanitation issues, it found them constitutionally adequate. Other sanitation issues, such as drinking water sanitation and absence of bedding cleaning procedure, were not found to rise to the level of unconstitutionality. However, the court did find that the constitution did require a level of hygiene in food preparation and kitchen sanitation that the prisons did not meet. The defendants would be required to implement a procedure to ensure basic sanitation practices. Issues of violence were found "endemic" to the system and warranting attention, but also "inevitable" and not unconstitutional. Similarly, it found the healthcare provided to inmates to be constitutionally adequate.

The court mandated that the defendants design a plan to address the constitutionally inadequate conditions and appoint a special master to evaluate the defendants' plan. Other remedial orders were issued by the court in this case, such as enjoining defendants from keeping prisoners in confinement without physical exercise for longer than one week. The defendants appointed Patrick D. McManus. In 1987, the court ordered the plans to be completed by 1992.

In a separate litigation concerning inmate populations at Tennessee penal institutions governed by the Grubbs population orders, the Sixth Circuit Court of Appeals (Judges Merritt, Nelson, and Lievely), remanded the case to the judge presiding over the Grubbs decree to oversee proceedings in that case consistent with the Grubbs order. Roberts v. Tennessee Department of Correction, 887 F.2d 1281. The Sixth Circuit noted that the Grubbs court should have jurisdiction of all matters pertaining to population limits and other matters of the Grubbs decree, and transferred the case to that judge.

On May 14, 1993, the matter came before the court regarding terminating the class action. The court (Judge Thomas A. Higgins) determined that conditions within Tennessee prisons had improved sufficiently to warrant the almost complete termination of court supervision, vacating and dissolving the injunction. Grubbs v. Bradley, 821 F.Supp. 496 (M.D.Tenn. 1993). The court retained jurisdiction in one area to ensure the defendants created a health care quality-assurance program. The court also awarded the plaintiffs' side attorney's fees and costs. The plaintiffs had moved to hold the defendants in contempt for violation of the injunction and the court denied without prejudice in 1999. The PACER docket indicates that defendants complied with this order and the docket ends on October 13, 2000 after several years of compliance review.

Angela Heverling - 05/18/2006
Richard Jolly - 11/14/2014
Chelsea Rinnig - 03/30/2018


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Issues and Causes of Action
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Issues
Affected Gender
Female
Male
Constitutional Clause
Cruel and Unusual Punishment
Content of Injunction
Monitor/Master
Crowding
Crowding / caseload
Pre-PLRA Population Cap
Defendant-type
Corrections
Jurisdiction-wide
General
Assault/abuse by residents/inmates/students
Bathing and hygiene
Conditions of confinement
Food service / nutrition / hydration
Recreation / Exercise
Sanitation / living conditions
Totality of conditions
Medical/Mental Health
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Tenn. Prison System
Tennessee Department of Corrections
Plaintiff Description All present and future adult inmates committed to the custody of the Tennessee Department of Correction (TDOC).
Indexed Lawyer Organizations ACLU National Prison Project
Legal Services/Legal Aid
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Attorneys fees
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Order Duration 1982 - 2000
Case Closing Year 2000
Case Ongoing No
Case Listing PC-TN-0004 : Tuggle v. Cook (M.D. Tenn.)
JC-TN-0005 : Carver v. Knox County (E.D. Tenn)
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)
80-3404 (M.D. Tenn.)
PC-TN-0007-9000.pdf | Detail
Date: 10/13/2000
Source: PACER [Public Access to Court Electronic Records]
General Documents
Order (887 F.2d 1281)
PC-TN-0007-0003.pdf | WESTLAW| LEXIS | Detail
Date: 10/05/1989
Source: Google Scholar
Memorandum (552 F.Supp. 1052) (M.D. Tenn.)
PC-TN-0007-0001.pdf | WESTLAW| LEXIS | Detail
Date: 08/13/1992
Source: Google Scholar
Memorandum (821 F.Supp. 496) (M.D. Tenn.)
PC-TN-0007-0002.pdf | WESTLAW| LEXIS | Detail
Date: 05/14/1993
Source: Google Scholar
Judges Higgins, Thomas Aquinas (M.D. Tenn.)
PC-TN-0007-0002 | PC-TN-0007-9000
Lively, Pierce (Sixth Circuit)
PC-TN-0007-0003
Merritt, Gilbert Stroud Jr. (Sixth Circuit)
PC-TN-0007-0003
Morton, Leland Clure (M.D. Tenn.)
PC-TN-0007-0001
Nelson, David Aldrich (Sixth Circuit)
PC-TN-0007-0003
Plaintiff's Lawyers Bonnyman, George G. Jr. (Tennessee)
PC-TN-0007-0001 | PC-TN-0007-0002 | PC-TN-0007-9000
Bronstein, Alvin J. (District of Columbia)
PC-TN-0007-0001
Calhoon, Kathryn F. (Tennessee)
PC-TN-0007-0001
Carter, O. Michael (Tennessee)
PC-TN-0007-0003
Charles, James Lawrence (Tennessee)
PC-TN-0007-0002 | PC-TN-0007-9000
Correll, Frank C. (Tennessee)
PC-TN-0007-0001
Croce, Lenny L. (Tennessee)
PC-TN-0007-0001
Grimes, R. Dale (Tennessee)
PC-TN-0007-0001
Holliday, Drake (Tennessee)
PC-TN-0007-0001
Kennedy, John Lee (Tennessee)
PC-TN-0007-0002 | PC-TN-0007-9000
Kipp, David C. Jr. (Tennessee)
PC-TN-0007-0002 | PC-TN-0007-9000
Knowles, E. Clifton (Tennessee)
PC-TN-0007-0001 | PC-TN-0007-0002 | PC-TN-0007-9000
Kozlowski, David Arthur (Tennessee)
PC-TN-0007-0001
Mahn, Michael J. (Tennessee)
PC-TN-0007-0003
Moore, Shawn F. (District of Columbia)
PC-TN-0007-0001
Overby, Russell J. (Tennessee)
PC-TN-0007-0001
Vanderbilt, Susan Kay (Tennessee)
PC-TN-0007-0001
Defendant's Lawyers Burson, Charles W. (Tennessee)
PC-TN-0007-0002 | PC-TN-0007-0003
Himmelreich, David M. (Tennessee)
PC-TN-0007-0003
Leech, William M. Jr. (Tennessee)
PC-TN-0007-0001
Littleton, Robert B. (Tennessee)
PC-TN-0007-0001
Pearingen, Michael D. (Tennessee)
PC-TN-0007-0001
Reevers, Stephanie (Tennessee)
PC-TN-0007-9000
Robinson, Charles E. (North Carolina)
PC-TN-0007-0002 | PC-TN-0007-9000
Small, Jennifer Helton (Tennessee)
PC-TN-0007-0001
Southworth, John F. Jr. (Tennessee)
PC-TN-0007-0001
Zimmerman, John C. (Tennessee)
PC-TN-0007-0001

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