On March 22, 1988, three female inmates brought suit in the U.S. District Court for the District of Columbia requesting declaratory and injunctive relief on grounds that the Federal Bureau of Prisons and various Federal Correctional Institutions violated their First, Fifth, and Eighth Amendment rights by placing them in the Female High Security Unit, the Bureau's highest security confinement institution for women.

A trial proceeding was held on the merits in order to consider Plaintiffs' motion for a preliminary injunction and Defendants' motion to dismiss. The District Court (Judge Barrington D. Parker) thereafter denied Plaintiffs' Eighth and Fifth Amendment claims but concluded that the Bureau's criteria for assigning women to the high security unit violated two of the three plaintiffs' First Amendment rights. Baraldini v. Meese, 691 F. Supp. 432 (D.D.C. 1988). Specifically, the court concluded that the Bureau policy of considering inmates' present and past affiliations was unconstitutionally overbroad and vague and that the policy was not reasonably related to legitimate penalogical interests. On this ground, the District Court granted two of the plaintiffs' requests for injunctive relief.

On appeal, the U.S. Court of Appeals for the D.C. Circuit (Judge Frank A. Kaufman) reversed and remanded, instructing the District Court to enter judgment for the Defendants. Baraldini v. Thornburgh, 884 F.2d 615 (D.C. Cir. 1989). The D.C. Circuit reasoned that, while the Bureau policies at issue were general, they were rationally related to a legitimate penalogical purpose and were not overly restrictive of First Amendment rights. Specifically, the court concluded that the Bureau's consideration of inmates' affiliations focused on whether the organizations with which the inmates associated had policies and practices of attempting to facilitate prison escapes of their members. The consideration was thus closely tied to security concerns.

On March 21, 1990, pursuant to the instructions of the D.C. Circuit, the District Court (Judge Aubrey E. Robinson) vacated the final judgment and entered judgment in favor of Defendants. The case appears to have been closed thereafter.

Vidhya Reddy - 03/04/2008


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