Sometime in 1979, an inmate at the Powhatan Correctional Center (PCC) filed a lawsuit under 42 U.S.C. § 1983 against the Virginia Department of Corrections in United States District Court in the Eastern District of Virginia alleging Eighth Amendment violations. Specifically, the inmate alleged that the totality of the conditions at PCC amounted to cruel and unusual punishment. Similar inmate cases were consolidated with the Cagle case on January 15, 1980 and on February 19, 1980. Plaintiffs, represented by private counsel, sought compensatory and declaratory relief.

On June 18, 1980, the plaintiffs filed an amended complaint and moved for class certification. The class was certified on October 7, 1980 to include present and future inmates at the Powhatan Correctional Center. During a hearing on the inmates' motion for a preliminary injunction, the District Court (Judge David Dortch Warriner) found that there was a "pervasive risk of harm" to prisoners at PCC. Negotiations followed, and the parties entered into a Consent Decree which was approved by the District Court on February 12, 1981. The Decree provided various forms of injunctive relief and contemplated continued supervision by the District Court through the filing of periodic compliance reports.

On April 26, 1996, the President signed the Prison Litigation Reform Act, which stated that prospective relief in prison conditions cases "shall extend no further than necessary to correct the violation of the Federal right of a particular plaintiff or plaintiffs." 18 U.S.C. § 3626(a)(1).

On March 14, 1997, the defendants filed a motion to terminate Consent Decree. On May 14, 1998, the District Court (Judge James R. Spencer) granted defendants' motion and vacated the Consent Decree. The class of inmates appealed.

On May 28, 1999, the United States Court of Appeals for the Fourth Circuit (Judge William Walter Wilkins) affirmed, holding that: (1) the PLRA was constitutional; (2) the PLRA did not provide an avenue for district courts to make, post hoc and nunc pro tunc, the findings required by the Act in order to avoid termination of a consent decree; (3) state did not waive the right to obtain termination of the decree; (4) the PLRA did not mandate an evidentiary hearing in all cases; and (5) there was no abuse of discretion in refusing to conduct an evidentiary hearing in the instant case.

On June 26, 2000, the Supreme Court denied the plaintiff's petition for writ of certiorari.

Emilee Baker - 11/02/2006


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