GPS RESEARCH LIBRARY: Prison conditions under the Eighth Amendment in Georgia's federal courts: what must be proved and what relief a court can order ============================================================ Georgia Prisoners' Speak — gps.press Generated: 2026-10-24 16:38:47 EDT Research Date: 2026-10-22 Topic: Eighth Amendment conditions-of-confinement law in the Eleventh Circuit: the elements, conditions decisions, staffing and violence, the Prison Litigation Reform Act, class certification, exhaustion, DOJ CRIPA suits and Georgia decrees JSON: https://gps.press/research-data/prison-conditions-under-the-eighth-amendment-in-georgias-federal-courts-what-must-be-proved-and-what-relief-a-court-can-order/?format=json SUMMARY ---------------------------------------- This collection sets out facts from public sources on the subject in its title, drawn from Georgia, federal sources, Alabama, Arizona, Arkansas, California, Connecticut, District of Columbia, Florida, Iowa, Louisiana, Maine, Massachusetts, Michigan, Mississippi, Missouri, New Hampshire, New Mexico, North Carolina, Texas, Utah, national and multi-state sources and other sources. Each entry gives a short statement, the exact passage from the source that supports it, and the source's title, web address and the date it was retrieved. Searches of a source that found no match are listed too, with the wordings that were tried. The entries record what each source said when it was retrieved. They aren't a complete account of the subject, and they don't add analysis or conclusions. LEGAL FACTS (370) ---------------------------------------- - [confirmed] Supreme Court affirmed 30-day cap on punitive isolation in Hutto v. Finney In an Eighth Amendment prison-conditions remedial case, the Supreme Court affirmed the Eighth Circuit. The District Court did not err in including a 30-day cap on punitive isolation as part of its comprehensive remedy, and the attorney's fee awards against the Department of Correction (for bad faith, and under the federal fees act) did not violate the Eleventh Amendment. Date: 1977-01-01 Tags: solitary,legal,conditions Sources: October Term, 1977 - [confirmed] Ross v. Blake: dead-end grievance procedure is unavailable An administrative grievance procedure is unavailable, and so need not be exhausted, when it operates as a simple dead end with officers unable or consistently unwilling to provide any relief to aggrieved inmates. Date: 2016-06-06 Tags: legal,policy Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA bars consent decrees not complying with § 3626(a) relief limits 18 U.S.C. § 3626 provides that in any civil action with respect to prison conditions, the court shall not enter or approve a consent decree unless it complies with the limitations on relief set forth in subsection (a). Tags: legal,policy,conditions Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Rule 23(a)(2) commonality requires a common contention capable of classwide resolution In Wal-Mart Stores, Inc. v. Dukes, the Supreme Court held that Rule 23(a)(2) requires a party seeking class certification to prove that the class's claims depend upon a common contention of such a nature that it is capable of classwide resolution, meaning that determination of its truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke. Date: 2011-06-20 Tags: legal,policy Sources: 338 October Term, 2010; Wal-Mart Stores, Inc. v. Dukes, Supreme Court of the United States, 2011-06-20 (court record via CourtListener) - [confirmed] AG intervention authority for egregious institutional conditions 42 U.S.C. § 1997c authorizes the Attorney General, upon motion, to intervene in any federal action seeking relief from egregious or flagrant conditions depriving institutionalized persons of constitutional or federal rights and causing grievous harm, where the AG has reasonable cause to believe the deprivation is pursuant to a pattern or practice of resistance to those rights. Tags: legal,policy,investigations Sources: Page 5245 TITLE 42—THE PUBLIC HEALTH AND WELFARE § 1997c - [confirmed] Hope v. Pelzer: hitching post violated Eighth Amendment In Hope v. Pelzer (October Term 2001), the Supreme Court held that attaching a prisoner to a hitching post under the alleged circumstances violated the Eighth Amendment, agreeing with the Eleventh Circuit, which had relied on circuit precedent and a DOJ report finding Alabama's systematic use of the hitching post to be improper corporal punishment. Date: 2001-01-01 Tags: legal,conditions Sources: October Term, 2001 - [confirmed] Farmer v. Brennan two-requirement test for Eighth Amendment conditions claims The Eleventh Circuit (Burton v. Espino, 2026) applied Farmer v. Brennan, holding a prisoner must meet 'two requirements': first, the deprivation must be objectively serious, and second, the official must have a sufficiently culpable state of mind (deliberate indifference). Date: 2026-08-25 Tags: legal,conditions,policy Sources: Jonathan Michael Burton v. Dr. G. Espino, Court of Appeals for the Eleventh Circuit, 2026-08-25 (court record via CourtListener) - [reported] DOJ CRIPA notice found Alabama violated prisoners' rights DOJ's CRIPA notice letter found Alabama violated prisoners' rights by failing to protect them from prisoner-on-prisoner violence and sexual abuse, and by failing to provide safe conditions, exacerbated by deficiencies in staffing and supervision and overcrowding. Tags: violence,staffing,conditions,investigations Sources: U.S. Department of Justice, dl - [confirmed] § 1983 creates liability for deprivation of federal rights under color of state law 42 U.S.C. § 1983 provides that every person who, under color of any statute, ordinance, regulation, custom, or usage of any State or Territory or the District of Columbia, subjects or causes to be subjected any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress. Tags: legal,policy Sources: law.cornell.edu: 1983 - [confirmed] McMahon v. Beard distinguished solitary cell from unsanitary-cell precedent The Fifth Circuit held that a solitary cell with a flush toilet, washbasin, shower, bed, and lights was clearly distinguishable from the line of cases focusing on unsanitary cell conditions, and found no suggestion of lack of food or issue as to cell size. Date: 1978-11-02 Tags: solitary,conditions,legal Sources: Raymond Alwyn McMahon v. Malcolm Beard, Sheriff of Hillsborough County, Florida, U.S. Court of Appeals, 5th Circuit, 1978-11-02 (court record via CourtListener) - [confirmed] Fifth Circuit recognizes Eighth Amendment right against extremely dangerous temperatures The Fifth Circuit in Bailey v. Collier stated it is well-established in that circuit that the Eighth Amendment guarantees inmates a right to be free from exposure to extremely dangerous temperatures without adequate remedial measures, citing Hinojosa v. Livingston, 807 F.3d 657, 669 (5th Cir. 2015), and that it has repeatedly upheld district court findings that heat levels within Texas prisons violate the Eighth Amendment. Date: 2017-08-18 Tags: conditions,legal,facilities Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [confirmed] DOJ opened CRIPA investigation into Georgia prisons in February 2016 The DOJ Civil Rights Division's Special Litigation Section opened a CRIPA investigation into conditions of confinement in Georgia prisons in February 2016, focused on protection from harm from sexual abuse. Date: 2016-02-01 Tags: legal,investigations,conditions Sources: Special Litigation Section Case Summaries - [confirmed] Harrison v. Culliver two-part deliberate indifference test In Harrison v. Culliver, the Eleventh Circuit held that a prisoner-plaintiff must first demonstrate an objectively substantial risk of serious harm to prisoners, then show the defendant was deliberately indifferent, which requires subjective knowledge of a risk of serious harm, disregard of that risk, and conduct that is more than gross negligence. Date: 2014-04-02 Tags: legal,conditions,violence Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [reported] Guthrie v. MacDougall filed October 1972 A 'Georgia Prisons' report states that the case Guthrie v. MacDougall was filed in October 1972 and had a hearing before Judge Anthony Alaimo on December 2, 1974. Tags: legal,conditions,policy Sources: Georgia Prisons - [confirmed] Farmer v. Brennan: deliberate indifference requires knowledge of substantial risk and disregard The Supreme Court held that a prison official may be held liable under the Eighth Amendment for acting with 'deliberate indifference' to inmate health or safety only if he knows that inmates face a substantial risk of serious harm and disregards that risk by failing to take reasonable measures to abate it. Tags: legal,conditions,policy Sources: October Term, 1993 - [confirmed] Definition of prisoner release order under § 3626 18 U.S.C. § 3626(4) defines a 'prisoner release order' to include any order, including a temporary restraining order or preliminary injunctive relief, that has the purpose or effect of reducing or limiting the prison population, or that directs the release from or nonadmission of prisoners to a prison. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: deliberate indifference requires subjective recklessness The Eleventh Circuit held in Swain v. Junior that the district court erred in holding that the defendants acted with a deliberately indifferent mental state, which is equivalent to 'subjective recklessness as used in the criminal law.' Date: 2020-06-15 Tags: legal,conditions,medical Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] PLRA automatic stay is mandatory and precludes equitable injunction (Miller v. French) Miller v. French holds that Congress clearly intended to make operation of the PLRA's automatic stay provision mandatory, precluding courts from exercising their equitable power to enjoin the stay. Tags: legal,policy Sources: MILLER, SUPERINTENDENT, PENDLETON CORRECTIONAL FACILITY, et al. v. FRENCH, et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Ross v. Blake: unknowable grievance scheme is unavailable An administrative remedy is unavailable when the scheme is so opaque that no ordinary prisoner can discern or navigate it, essentially 'unknowable.' Date: 2016-06-06 Tags: legal,policy Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA permits private settlement agreements outside court enforcement 18 U.S.C. § 3626 provides that nothing in the section precludes parties from entering a private settlement agreement that does not comply with subsection (a) relief limits, if its terms are not subject to court enforcement other than reinstatement of the civil proceeding; parties claiming breach may seek remedies in State court under State law. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Rule 23(b)(2) excludes individualized monetary relief such as backpay In Wal-Mart Stores v. Dukes, the Supreme Court held that Rule 23(b)(2) applies only when a single, indivisible remedy would provide relief to each class member, so that claims for individualized monetary relief such as backpay are excluded from (b)(2) certification. The Court also concluded that the plaintiffs' claims for backpay were improperly certified under Rule 23(b)(2). Date: 2011-06-20 Tags: legal,policy Sources: 338 October Term, 2010; Wal-Mart Stores, Inc. v. Dukes, Supreme Court of the United States, 2011-06-20 (court record via CourtListener) - [confirmed] CRIPA does not restrict other parties' enforcement authority 42 U.S.C. § 1997j provides that the subchapter does not expand or restrict the authority of parties other than the United States to enforce legal rights of institutionalized persons, and that a pending AG investigation or contemplated litigation is not grounds to delay or prejudice litigation by other parties. Tags: legal,policy Sources: § 1997f TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5248 - [reported] Chandler v. Baird: district court's 'trilogy' cannot preclude fact-intensive Eighth Amendment inquiry The Eleventh Circuit stated that the district court was beguiled by a simplistic trilogy of conditions that, while convenient as illustrative shorthand, cannot preclude a fact-intensive inquiry under constitutional standards. Date: 1991-03-15 Tags: legal,conditions Sources: Chandler v. Baird, U.S. Court of Appeals, 11th Circuit, 1991-03-15 (court record via CourtListener) - [confirmed] Hope v. Pelzer: qualified immunity reversed; fair warning standard Reviewing a summary judgment granting qualified immunity, the Supreme Court held that handcuffing Hope to a hitching post as alleged was a clear Eighth Amendment violation and that the guards had fair warning because a prior case need not be 'materially similar', Eleventh Circuit precedent, an ADOC regulation, and a DOJ report gave notice. The Court reversed the grant of qualified immunity. Date: 2001-01-01 Tags: legal,conditions Sources: October Term, 2001 - [confirmed] Wilson v. Seiter: conditions-of-confinement claims require culpable state of mind Multiple circuits (4th, 6th, 7th) in 2026 applied Wilson v. Seiter, 501 U.S. 294, 303-05 (1991), which requires a culpable state of mind for conditions-of-confinement and medical-care claims under the Eighth Amendment. Tags: legal,conditions,medical Sources: Kevin Smith v. Christopher Price, Court of Appeals for the Seventh Circuit, 2026-08-19 (court record via CourtListener); Theodore Bolick v. Joel Anderson, Court of Appeals for the Fourth Circuit, 2026-03-13 (court record via CourtListener); Machelle Pearson v. MDOC, Court of Appeals for the Sixth Circuit, 2026-03-26 (court record via CourtListener) - [reported] Andrews v. Biggers follows Purcell v. Toombs County on Eleventh Amendment immunity In Oqueshia Andrews v. Carmel Biggers, Jr. (11th Cir., 2021-05-07), the court followed Purcell v. Toombs County, 400 F.3d 1313 (11th Cir. 2005), regarding Eleventh Amendment immunity analysis. The opinion cites Pounds in connection with the Purcell line of authority. Date: 2021-05-07 Tags: legal Sources: Oqueshia Andrews v. Carmel Biggers, Jr., Court of Appeals for the Eleventh Circuit, 2021-05-07 (court record via CourtListener) - [confirmed] 1996 amendment limits injunctive relief against judicial officers under § 1983 The 1996 amendment to 42 U.S.C. § 1983 (Pub. L. 104-317) added a proviso that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. Date: 1996-01-01 Tags: legal,policy Sources: law.cornell.edu: 1983 - [confirmed] DOJ expanded Georgia prisons investigation in September 2021 to violence In September 2021 the DOJ Civil Rights Division expanded its Georgia prisons CRIPA investigation to include protection of incarcerated individuals in Georgia's medium and close security prisons from violence by other incarcerated individuals. Date: 2021-09-01 Tags: legal,investigations,violence Sources: Special Litigation Section Case Summaries - [confirmed] Farmer v. Brennan adopts subjective recklessness test, rejects objective test The Court held that subjective recklessness, as used in the criminal law, is the appropriate test for 'deliberate indifference,' and rejected petitioner's invitation to adopt a purely objective test for determining liability. The Eighth Amendment outlaws cruel and unusual 'punishments,' not 'conditions,' and the failure to alleviate a significant risk that an official should have perceived but did not cannot be condemned as infliction of punishment. Tags: legal,conditions Sources: October Term, 1993 - [confirmed] Definition of consent decree under § 3626 18 U.S.C. § 3626(1) defines a 'consent decree' as any relief entered by the court that is based in whole or in part upon the consent or acquiescence of the parties but does not include private settlements. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: deliberate indifference is more onerous than negligence The Eleventh Circuit emphasized that the deliberate indifference standard is far more onerous than normal tort-based standards of conduct and is not a constitutionalized version of common-law negligence. Date: 2020-06-15 Tags: legal,conditions Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] PLRA automatic stay does not violate separation of powers (Miller v. French) Miller v. French holds that 18 U.S.C. § 3626(e) does not violate separation of powers principles. The Constitution prohibits one branch of the Government from encroaching on the central prerogatives of another. Tags: legal,policy Sources: MILLER, SUPERINTENDENT, PENDLETON CORRECTIONAL FACILITY, et al. v. FRENCH, et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Ross v. Blake: administrator thwarting makes remedy unavailable An administrative remedy is unavailable when prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation. Date: 2016-06-06 Tags: legal,corruption Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA definition of 'prisoner release order' 18 U.S.C. § 3626 defines 'prisoner release order' to include any order, including a temporary restraining order or preliminary injunctive relief, that has the purpose or effect of reducing or limiting the prison population, or that directs the release from or nonadmission of prisoners to a prison. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626; law.cornell.edu: 3626 - [confirmed] Wal-Mart reversed nationwide Title VII class for failure to prove companywide policy The Supreme Court reversed certification of a nationwide Title VII class in Wal-Mart v. Dukes, holding that the plaintiffs failed the commonality requirement because they offered no convincing proof of a companywide discriminatory pay and promotion policy. Tags: legal Sources: 338 October Term, 2010 - [confirmed] Three-judge district court convening requirement 28 U.S.C. § 2284 provides that a district court of three judges shall be convened when required by Act of Congress or when an action challenges the constitutionality of congressional or statewide legislative apportionment. Tags: legal Sources: law.cornell.edu: 2284 - [confirmed] Helling v. McKinney: exposure to secondhand smoke can state Eighth Amendment claim In Helling v. McKinney, the Supreme Court affirmed that a prisoner states a cause of action under the Eighth Amendment by alleging that prison officials, with deliberate indifference, exposed him to levels of environmental tobacco smoke that pose an unreasonable risk of serious damage to his future health. Date: 1993-01-01 Tags: legal,conditions,medical Sources: Helling v. McKinney, 509 U.S. 25 (1993). - [confirmed] Helling v. McKinney: conditions claims need not await a tragic event The Seventh Circuit (Smith v. Price, 2026) and Fourth Circuit (Hammock v. Watts, 2025) applied Helling v. McKinney, 509 U.S. 25, 33 (1993), holding that prison-conditions claims 'need not await a tragic event' and can address future harm such as exposure to communicable disease or unsafe drinking water. Tags: legal,conditions,medical Sources: Kevin Smith v. Christopher Price, Court of Appeals for the Seventh Circuit, 2026-08-19 (court record via CourtListener); Machelle Pearson v. MDOC, Court of Appeals for the Sixth Circuit, 2026-03-26 (court record via CourtListener); Terrence Hammock v. Gail Watts, Court of Appeals for the Fourth Circuit, 2025-07-23 (court record via CourtListener) - [reported] Fifth Circuit: Hope v. Pelzer obviousness exception does not relieve plaintiffs of burden In Thorpe v. Weaver (5th Cir., 2026-07-08), the court explained that Hope v. Pelzer's obviousness exception does not relieve plaintiffs of their burden. The opinion states: "Hope v. Pelzer's obviousness exception does not relieve plaintiffs of the" (sentence truncated in source text). Date: 2026-07-08 Tags: legal Sources: Thorpe v. Weaver, Court of Appeals for the Fifth Circuit, 2026-07-08 (court record via CourtListener) - [confirmed] Chandler v. Crosby: heat on death row not unconstitutionally excessive In Chandler v. Crosby, the Eleventh Circuit affirmed the district court's judgment after a bench trial, holding that summertime cell temperatures on Florida's death row unit were not unconstitutionally excessive and that the prisoners had not cleared the high bar required to show an Eighth Amendment violation. Date: 2004-08-06 Tags: conditions,legal Sources: Chandler v. Crosby, U.S. Court of Appeals, 11th Circuit, 2004-08-06 (court record via CourtListener) - [confirmed] Keohane v. Florida DOC explained Thomas v. Bryant 'reimagining' The Eleventh Circuit in Keohane v. Florida Department of Corrections Secretary explained Thomas v. Bryant, 614 F.3d 1288 (11th Cir. 2010), describing it as 'reimagin[ing]' Thomas's holding. Date: 2020-12-03 Tags: legal Sources: Reiyn Keohane v. Florida Department of Corrections Secretary, Court of Appeals for the Eleventh Circuit, 2020-12-03 (court record via CourtListener) - [confirmed] DOJ announced Georgia prisons investigation September 14, 2021 The Justice Department announced on Tuesday, September 14, 2021 its investigation into conditions in Georgia prisons. Date: 2021-09-14 Tags: legal,investigations Sources: DOJ Press Release: Justice Department Announces Investigation into Conditions in Georgia Prisons - [reported] DOJ proposed consent decree with Fulton County Jail (Jan 3, 2025) On Friday, January 3, 2025, the Justice Department announced it had entered into a proposed, court-enforceable consent decree with Fulton County, Georgia, and the Fulton County Sheriff's Office to resolve CRIPA findings that conditions inside the Fulton County Jail violate the Constitution and other federal laws. Date: 2025-01-03 Tags: legal,conditions,investigations,facilities Sources: Justice Department Reaches Proposed Consent Decree with Fulton County, U.S. DOJ - [confirmed] Farmer v. Brennan: deliberate indifference is more than negligence but less than intentional harm The Court stated that while Estelle establishes that deliberate indifference entails something more than mere negligence, the cases are also clear that it is satisfied by something less than acts or omissions for the very purpose of causing harm. Tags: legal,conditions Sources: October Term, 1993 - [confirmed] Definition of private settlement agreement under § 3626 18 U.S.C. § 3626(6) defines a 'private settlement agreement' as an agreement entered into among the parties that is not subject to judicial enforcement other than the reinstatement of the civil proceeding that the agreement settled. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: Eleventh Circuit vacated COVID-19 injunction at Metro West On the county's appeal of a preliminary injunction ordering COVID-19 measures at Metro West Detention Center, the Eleventh Circuit held the district court erred in issuing the injunction, chiefly because the plaintiffs had not shown the defendants acted with deliberate indifference (subjective recklessness), and it vacated the injunction and remanded. Date: 2020-06-15 Tags: legal,medical,conditions Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] Court may not terminate prospective relief if ongoing violation remains (Miller v. French) Miller v. French states that a court may not terminate prospective relief if it makes written findings based on the record that prospective relief remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary to correct the violation, and is narrowly drawn and the least intrusive means to correct the violation. Tags: legal,policy Sources: MILLER, SUPERINTENDENT, PENDLETON CORRECTIONAL FACILITY, et al. v. FRENCH, et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Ross v. Blake: three categories of unavailable remedies Ross v. Blake identified three circumstances in which an administrative remedy, though officially on the books, is not capable of use to obtain relief and is therefore 'unavailable': dead-end procedures, opaque/unknowable schemes, and administrator thwarting via machination, misrepresentation, or intimidation. Date: 2016-06-06 Tags: legal,policy Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA definition of 'prospective relief' 18 U.S.C. § 3626 defines 'prospective relief' to mean all relief other than compensatory monetary damages. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [reported] Braggs Phase 2A: staffing remedy question was modification, not PLRA need-narrowness-intrusiveness In the Phase 2A Omnibus Remedial Opinion in Braggs v. Dunn, the court stated that while the question for other remedial issues was whether the relief proposed by the plaintiffs satisfied the need-narrowness-intrusiveness standard of the PLRA, the question as to correctional staffing was whether and how the existing remedy should be modified in light of changed circumstances, such as the effects of the COVID-19 pandemic, and in recognition of the existing deadline's implausibility at that juncture. Tags: legal,staffing,policy Sources: Case 2:14-cv-00601-MHT-JTA Document 3461 Filed 12/27/21 Page 1 of 49 - [confirmed] Procedure for designating three-judge court 28 U.S.C. § 2284 provides that upon a request for three judges, the judge presented with the request shall, unless he determines three judges are not required, immediately notify the chief judge of the circuit, who shall designate two other judges, at least one of whom shall be a circuit judge. Tags: legal Sources: law.cornell.edu: 2284 - [confirmed] Helling v. McKinney: deliberate indifference judged by current attitudes and conduct on remand In Helling v. McKinney, the Court stated that on remand the subjective factor, deliberate indifference, should be determined in light of the prison authorities' current attitudes and conduct, which may have changed considerably since the judgment of the Court of Appeals. Date: 1993-01-01 Tags: legal Sources: Helling v. McKinney, 509 U.S. 25 (1993). - [confirmed] Hamm v. DeKalb County: floor mattress and food standards The Eleventh Circuit (Jacoby v. Baldwin County, 2016; Bilal v. GEO Care, 2020; Melton v. Abston, 2016) applied Hamm v. DeKalb County, 774 F.2d 1567 (11th Cir. 1985), holding that temporarily sleeping on a mattress on the floor or a table is not necessarily a constitutional violation, that food must be minimally adequate, and that the state cannot completely deny medical care or provide care 'below some minimally adequate level.' Tags: legal,conditions,medical,facilities Sources: Brent Jacoby v. Baldwin County, Court of Appeals for the Eleventh Circuit, 2016-08-29 (court record via CourtListener); Walter Melton v. David Abston, Court of Appeals for the Eleventh Circuit, 2016-11-18 (court record via CourtListener); Jamaal Ali Bilal v. Geo Care, LLC, Court of Appeals for the Eleventh Circuit, 2020-11-23 (court record via CourtListener) - [confirmed] Newman v. Alabama: basic necessities of life prisoners may not be denied Newman v. Alabama (5th Cir.) is the earliest opinion found stating that the basic necessities of life prisoners may not be denied include reasonably adequate food, clothing, shelter, sanitation, and necessary medical attention. It rested this on earlier Fifth Circuit cases (Gates v. Collier, 501 F.2d 1291; Newman v. Alabama, 503 F.2d 1320), not on a statute. Hamm v. DeKalb County cites Newman for the rule. Date: 1977-01-01 Tags: legal,conditions,medical Sources: Court record, U.S. Court of Appeals, 5th Circuit, 1977-11-07 (court record via CourtListener) - [confirmed] Chandler v. Crosby: Eighth Amendment applies to cooling and ventilation claims In Chandler v. Crosby, the Eleventh Circuit held that the Eighth Amendment applies to prisoner claims of inadequate cooling and ventilation, and that cooling and ventilation are distinct prison conditions such that a prisoner may state a claim by alleging a deficiency as to either in isolation or both in combination. Date: 2004-08-06 Tags: conditions,legal Sources: Chandler v. Crosby, U.S. Court of Appeals, 11th Circuit, 2004-08-06 (court record via CourtListener) - [confirmed] PLRA § 3626(a)(1)(A) narrow-tailoring requirements for prospective relief The Eleventh Circuit in Georgia Advocacy Office v. Theodore Jackson described 18 U.S.C. § 3626(a)(1)(A) as requiring courts to find that prospective relief in prison-conditions cases is narrowly drawn, extends no further than necessary to correct the violation of the federal right, and is the least intrusive means necessary to correct the violation, with substantial weight given to any adverse impact on public safety or the operation of a criminal justice system caused by the relief. Date: 2021-07-14 Tags: legal,policy Sources: Georgia Advocacy Office v. Theodore Jackson, U.S. Court of Appeals, 11th Circuit, 2021-07-14 (court record via CourtListener) - [confirmed] 33 weapon assaults insufficient to show violence and terror reign In Harrison v. Culliver, the Eleventh Circuit held that evidence of 33 incidents involving weapons at an institution housing 830 to 990 inmates, only four of which occurred on the back hallway, was hardly sufficient to demonstrate that the prison was one where violence and terror reign. Date: 2014-04-02 Tags: legal,violence,facilities Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [confirmed] Farmer v. Brennan vacates summary judgment for officials and remands Rejecting an objective test, the Supreme Court held that a prison official is liable under the Eighth Amendment for denying humane conditions only if the official knows of and disregards an excessive risk to inmate health or safety (subjective recklessness); it vacated summary judgment for the officials and remanded. Tags: legal,conditions Sources: October Term, 1993 - [confirmed] Definition of civil action with respect to prison conditions under § 3626 18 U.S.C. § 3626(2) defines a 'civil action with respect to prison conditions' as any civil proceeding arising under Federal law with respect to the conditions of confinement or the effects of actions by government officials on the lives of persons confined in prison, but does not include habeas corpus proceedings challenging the fact or duration of confinement in prison. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: defendants acted reasonably 'doing their best' amid COVID-19 The Eleventh Circuit held that it could not conclude that the defendants acted unreasonably by doing their best when faced with a perfect storm of a contagious virus and space constraints inherent in a correctional facility, and that because the defendants acted reasonably, they cannot be found liable under the Eighth Amendment. Date: 2020-06-15 Tags: legal,medical,conditions Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] LaMarca v. Turner: ordering guard discipline intruded on prison operations In LaMarca v. Turner, the Eleventh Circuit held that the district court's order requiring Lambdin to discipline his guards, detailing the type of sanctions and conditions for their use, unnecessarily intruded on GCI's operations and was an inappropriate use of the court's equity powers; it was sufficient that the court enjoined Lambdin to ensure the specific protective policies were carried out. Date: 1993-01-01 Tags: legal,staffing,violence Sources: 995 F.2d 1526 (1993) - [confirmed] Ross v. Blake rejects 'special circumstances' exception The Supreme Court rejected the Fourth Circuit's unwritten 'special circumstances' exception to PLRA exhaustion as inconsistent with the statute, while affirming that a prisoner need not exhaust remedies that are not 'available.' Date: 2016-06-06 Tags: legal Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA definition of 'civil action with respect to prison conditions' 18 U.S.C. § 3626 defines 'civil action with respect to prison conditions' as any civil proceeding arising under Federal law regarding conditions of confinement or effects of government officials' actions on confined persons' lives, excluding habeas corpus proceedings challenging the fact or duration of confinement. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [reported] Braggs Phase 2A: February 2022 deadline to meet Savage-recommended ADOC staffing levels In the Phase 2A Omnibus Remedial Opinion in Braggs v. Dunn, the court noted that the central remaining provision of the correctional understaffing relief was a deadline of February 2022 for ADOC to achieve the staffing levels recommended by the defendants' own staffing experts, Margaret and Merle Savage. Tags: legal,staffing Sources: Case 2:14-cv-00601-MHT-JTA Document 3461 Filed 12/27/21 Page 1 of 49 - [confirmed] Appeal of three-judge court injunction orders to Supreme Court 28 U.S.C. § 1253 provides that, except as otherwise provided by law, any party may appeal to the Supreme Court from an order granting or denying, after notice and hearing, an interlocutory or permanent injunction in any civil action required by Act of Congress to be heard and determined by a district court of three judges. Tags: legal Sources: law.cornell.edu: 1253 - [confirmed] Farmer v. Brennan: deliberate indifference requires actual knowledge and disregard of excessive risk In Farmer v. Brennan, the Supreme Court rejected an objective test for deliberate indifference and held that a prison official cannot be found liable under the Eighth Amendment for denying an inmate humane conditions of confinement unless the official knows of and disregards an excessive risk to inmate health or safety; the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and must also draw that inference. Date: 1994-01-01 Tags: legal,conditions Sources: Farmer v. Brennan, 511 U.S. 825 (1994). - [confirmed] Brooks v. Warden: physical-injury requirement limits emotional-injury claims The Eleventh Circuit (Hoever v. Marks, 2021; Nelson v. Sellers, 2024; Bilal v. GEO Care, 2020) applied Brooks v. Warden, 800 F.3d 1295 (11th Cir. 2015), which bars claims for emotional injury absent physical injury and rejects a 'mere possibility' of injury as sufficient. Tags: legal,conditions Sources: Jamaal Ali Bilal v. Geo Care, LLC, Court of Appeals for the Eleventh Circuit, 2020-11-23 (court record via CourtListener); Conrad L. Hoever v. R. Marks, Court of Appeals for the Eleventh Circuit, 2021-04-09 (court record via CourtListener); Jerry Nelson v. Keyvon Sellers, Court of Appeals for the Eleventh Circuit, 2024-01-05 (court record via CourtListener) - [confirmed] Newman v. Alabama: Eighth Amendment duty ceiling Newman v. Alabama (5th Cir.) stated the rule as a ceiling on the Eighth Amendment duty: if the State furnishes reasonably adequate food, clothing, shelter, sanitation, medical care and personal safety, that ends its obligations under the Eighth Amendment. Date: 1977-01-01 Tags: legal,conditions Sources: Court record, U.S. Court of Appeals, 5th Circuit, 1977-11-07 (court record via CourtListener) - [reported] Sixth Circuit applies Hope v. Pelzer to denial of bathroom breaks and confinement conditions In Mark Charlton-Perkins v. Univ. of Cincinnati (6th Cir., 2026-08-05), the court followed Hope v. Pelzer, 536 U.S. 730, 738 (2002), in the context of bathroom breaks and when a prisoner was confined. The opinion text reads: "bathroom breaks, Hope v. Pelzer, 536 U.S. 730, 738 (2002), and when a prisoner was confined in" (sentence truncated in source text). Date: 2026-08-05 Tags: legal,conditions Sources: Mark Charlton-Perkins v. Univ. of Cincinnati, Court of Appeals for the Sixth Circuit, 2026-08-05 (court record via CourtListener) - [confirmed] Chandler v. Crosby: heat analysis considers severity and duration; mere discomfort insufficient In Chandler v. Crosby, the Eleventh Circuit held that the Eighth Amendment analysis of heat conditions is concerned with both the severity and the duration of the prisoner's exposure to inadequate cooling and ventilation, and that a prisoner's mere discomfort, without more, does not offend the Eighth Amendment. Date: 2004-08-06 Tags: conditions,legal Sources: Chandler v. Crosby, U.S. Court of Appeals, 11th Circuit, 2004-08-06 (court record via CourtListener) - [confirmed] Cason v. Seckinger: underlying suit filed in 1984 over Middle Georgia Correctional Complex conditions In Cason v. Seckinger, the underlying civil action seeking injunctive relief from allegedly unconstitutional prison conditions at the Middle Georgia Correctional Complex was originally filed in 1984. Date: 1984-01-01 Tags: legal,conditions,facilities Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [reported] No formal DOJ-Georgia resolution as of February 22, 2025 DOJ concluded its findings report by informing Georgia it hoped to reach a consensual resolution, but the Attorney General may initiate a CRIPA lawsuit if Georgia officials do not satisfactorily address DOJ's concerns; as of February 22, 2025, DOJ and Georgia had not reached a formal resolution. Date: 2025-02-22 Tags: legal,investigations Sources: DOJ Investigation of Georgia Prisons, Civil Rights Litigation Clearinghouse - [confirmed] Weapon assaults did not approach constant threat of violence In Harrison v. Culliver, the Eleventh Circuit held that although assaults did occur throughout Holman prison and some involved weapons, the evidence of inmate-on-inmate assault involving weapons did not indicate that inmates were exposed to something even approaching the constant threat of violence. Date: 2014-04-02 Tags: legal,violence Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [confirmed] Brooks v. Warden: health risks of prolonged exposure to human excrement are obvious In Brooks v. Warden, the Eleventh Circuit reversed the dismissal of a prisoner's Eighth Amendment claim that he was forced to defecate in his jumpsuit and sit in his own feces for two days while chained in a hospital bed, holding that the health risks of prolonged exposure to human excrement are obvious and satisfy the objective element of an Eighth Amendment violation. Date: 2015-09-03 Tags: legal,conditions,medical Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Postponement of automatic stay limited to 60 days for good cause Under 18 U.S.C. § 3626, an automatic stay under subsection (e)(2)(A) may be postponed for not more than 60 days for good cause, and no postponement is permissible because of general congestion of the court's calendar. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: PLRA exhaustion and Monell issues separately assessed In reviewing the district court's deliberate-indifference ruling, the Eleventh Circuit stated it would also separately assess whether the district court erred in refusing to address the defendants' contention that the plaintiffs failed to properly exhaust available administrative remedies under the Prison Litigation Reform Act, and the heightened standards for municipal liability under Monell. Date: 2020-06-15 Tags: legal,policy Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] LaMarca v. Turner: equitable relief limited to targeting existing wrong In LaMarca v. Turner, the Eleventh Circuit stated that absent an existing constitutional violation, a district court's power to grant equitable relief is limited to ensuring the prison continues to provide adequate protection, because while district courts have broad discretion to fashion equitable relief, such relief must target the existing wrong, citing Milliken v. Bradley that federal-court decrees exceed appropriate limits if aimed at eliminating a condition that does not violate the Constitution or does not flow from such a violation. Date: 1993-01-01 Tags: legal,conditions Sources: 995 F.2d 1526 (1993) - [confirmed] Ross v. Blake: exhaustion is mandatory absent unavailability The PLRA's mandatory exhaustion language means a court may not excuse a failure to exhaust, even to take special circumstances into account. Date: 2016-06-06 Tags: legal Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] PLRA definitions of 'consent decree' and 'private settlement agreement' 18 U.S.C. § 3626 defines 'consent decree' as any relief entered by the court based in whole or in part on the consent or acquiescence of the parties, excluding private settlements; 'private settlement agreement' means an agreement among the parties not subject to judicial enforcement other than reinstatement of the settled civil proceeding. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Farmer v. Brennan: knowledge may be inferred from obvious risk but is not required In Farmer v. Brennan, the Court stated that a trier of fact may infer knowledge of a substantial risk from the very fact that the risk was obvious, but that it is not required to do so. Date: 1994-01-01 Tags: legal Sources: Farmer v. Brennan, 511 U.S. 825 (1994). - [confirmed] Ross v. Blake: exhaustion limited to remedies actually available The Fourth, Seventh, and Eighth Circuits (2026) applied Ross v. Blake, 578 U.S. 632 (2016), holding an inmate need exhaust only those remedies actually available to him; a remedy 'on the books' that is unavailable need not be exhausted. Tags: legal,policy Sources: Lawrence Burns v. Sterling Polk, Court of Appeals for the Seventh Circuit, 2026-08-18 (court record via CourtListener); Benjamin Carter v. Beth Cabell, Court of Appeals for the Fourth Circuit, 2026-08-04 (court record via CourtListener); Aura Lopez-Lopez v. Todd Blanche, Court of Appeals for the Eighth Circuit, 2026-07-07 (court record via CourtListener) - [confirmed] Parsons v. Ryan certified statewide class and isolation subclass In Parsons v. Ryan, the Ninth Circuit affirmed certification of a statewide class of Arizona prisoners challenging ADC medical, dental and mental health care policies, and a subclass challenging ADC isolation unit policies, defining the class as all prisoners now or in the future subjected to the medical, mental health, and dental care policies and practices of the ADC. Date: 2014-01-01 Tags: legal,medical,mental_health,solitary Sources: Victor Parsons v. Charles Ryan, U.S. Court of Appeals, 9th Circuit, 2014-06-05 (court record via CourtListener) - [confirmed] Chandler v. Crosby: prisoners did not clear high Eighth Amendment bar Chandler v. Crosby states that under the standards applied, the court could not say that the prisoners at the Unit had cleared the high bar the Eighth Amendment conditions-of-confinement standard requires. Date: 2004-08-06 Tags: conditions,legal Sources: Chandler v. Crosby, U.S. Court of Appeals, 11th Circuit, 2004-08-06 (court record via CourtListener) - [confirmed] Geraghty relation-back doctrine for erroneous denial of class certification In U.S. Parole Comm'n v. Geraghty, the Supreme Court held that where an action would have acquired independent legal class status but for the district court's erroneous denial of class certification, a corrected ruling on appeal 'relates back' to the erroneous denial. Date: 2013-04-16 Tags: legal Sources: Genesis HealthCare Corp. v. Symczyk, Supreme Court of the United States, 2013-04-16 (court record via CourtListener) - [confirmed] Cason v. Seckinger: Eleventh Circuit vacated partial termination and remanded In Cason v. Seckinger, the Eleventh Circuit vacated the portion of the district court's order denying an evidentiary hearing and partially terminating the consent decrees, and remanded the case for further proceedings. Date: 2000-10-24 Tags: legal,policy Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [reported] Harrison v. Culliver followed Purcell v. Toombs County Later treatment: Harrison v. Culliver, F.3d 11th Cir, followed Purcell v. Toombs County, F.3d 11th Cir. Date: 2014-04-02 Tags: legal Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [confirmed] Brooks v. Warden: sanitation claim requires no allegation of pain In Brooks v. Warden, the Eleventh Circuit held that the Baird decision's holding that the plaintiff's sanitation claim defeated summary judgment did not require any allegation of pain, and that Brooks had sufficiently alleged a substantial risk of serious harm. Date: 2015-09-03 Tags: legal,conditions Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Court may postpone effective date of automatic stay under § 3626 18 U.S.C. § 3626(3) provides that the court may postpone the effective date of an automatic stay. Tags: legal,policy Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] LaMarca v. Turner: injunction affirmed for rape-victim training and referral In LaMarca v. Turner, the Eleventh Circuit affirmed the portion of the district court's injunction ordering Lambdin to provide training to all prison guards in handling rape complaints, require special training for the staff psychiatrist and psychologist, and promulgate an official referral procedure for rape victims, because that aspect of the injunction was based on well-supported independent findings that inmates were systematically denied post-rape psychological or psychiatric counseling, constituting deliberate indifference to a serious medical need. Date: 1993-01-01 Tags: legal,mental_health,violence,medical Sources: 995 F.2d 1526 (1993) - [confirmed] Turner v. Burnside: retaliation makes remedy unavailable A prison official's serious threats of substantial retaliation against an inmate for lodging or pursuing a grievance make the administrative remedy 'unavailable' if (1) the threat actually deterred the inmate and (2) it would deter a reasonable inmate of ordinary firmness and fortitude. Date: 2008-08-28 Tags: legal,corruption Sources: Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener) - [confirmed] Legislative history of 18 U.S.C. § 3626 The source note to 18 U.S.C. § 3626 states the section was added by Pub. L. 103-322, title II, § 20409(a), Sept. 13, 1994, 108 Stat. 1827, and amended by Pub. L. 104-134 (Apr. 26, 1996) and Pub. L. 105-119, title I, § 123(a), Nov. 26, 1997, 111 Stat. 2470. Tags: legal,legislation Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Prisoner release order requires clear and convincing evidence crowding is primary cause 18 U.S.C. § 3626 provides that a three-judge court shall enter a prisoner release order only if it finds by clear and convincing evidence that crowding is the primary cause of the violation of a federal right and that no other relief will remedy the violation. Tags: legal,policy Sources: 18 USC 3626: Appropriate remedies with respect to prison conditions - [confirmed] Farmer v. Brennan: reasonable response to known risk shields officials from liability In Farmer v. Brennan, the Court stated that prison officials who actually knew of a substantial risk to inmate health or safety may be found free from liability if they responded reasonably to the risk, even if the harm ultimately was not averted. Date: 1994-01-01 Tags: legal Sources: Farmer v. Brennan, 511 U.S. 825 (1994). - [confirmed] Jones v. Bock: no pleading requirement to show exhaustion The Fourth, Sixth, and Eighth Circuits (2026) applied Jones v. Bock, 549 U.S. 199, 216 (2007), holding inmates need not plead or demonstrate exhaustion in their complaints and that prison rules, not the PLRA, define proper exhaustion. Tags: legal,policy Sources: Benjamin Carter v. Beth Cabell, Court of Appeals for the Fourth Circuit, 2026-08-04 (court record via CourtListener); Danyale Tubbs v. Sherry Payton, Court of Appeals for the Sixth Circuit, 2026-09-10 (court record via CourtListener); Nuuh Na'im v. James Beck, Court of Appeals for the Eighth Circuit, 2026-04-15 (court record via CourtListener) - [confirmed] Parsons v. Ryan: systemic policy claims satisfy commonality In Parsons v. Ryan, the Ninth Circuit rejected defendants' argument that Eighth Amendment healthcare and conditions-of-confinement claims can never satisfy Dukes commonality, explaining that the complaint did not allege that care on any particular occasion to any particular inmate was insufficient, but rather that ADC policies and practices of statewide and systemic application expose all inmates in ADC custody to a substantial risk of serious harm, a claim type the court held is firmly established under Helling v. McKinney and Farmer v. Brennan. Date: 2014-01-01 Tags: legal,medical,mental_health,conditions Sources: Victor Parsons v. Charles Ryan, U.S. Court of Appeals, 9th Circuit, 2014-06-05 (court record via CourtListener) - [confirmed] LaMarca v. Turner: staffing failures supported deliberate indifference finding In LaMarca v. Turner, the Eleventh Circuit held that evidence of improper and inadequate staff training, a staff out of control who did not report rapes and assaults, failure to supervise staff, and failure to station officers to patrol dormitories particularly at night supported a finding that the superintendent could have but did not take steps to minimize the risk of inmate violence. Date: 1993-07-07 Tags: staffing,violence,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Relation-back doctrine may apply to inherently transitory claims The Supreme Court has held that the relation-back doctrine may apply in Rule 23 cases where the claims raised are so inherently transitory that the trial court will not have even enough time to rule on a motion for class certification before the proposed representative's individual interest expires. Date: 2013-04-16 Tags: legal Sources: Genesis HealthCare Corp. v. Symczyk, Supreme Court of the United States, 2013-04-16 (court record via CourtListener) - [confirmed] Cason v. Seckinger: refusal of evidentiary hearing was abuse of discretion The Eleventh Circuit held that it was an abuse of discretion for the district court to refuse plaintiffs an evidentiary hearing on whether there were current and ongoing violations of class members' federal rights before terminating the consent decrees. Date: 2000-10-24 Tags: legal Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Hale three-element test for Eighth Amendment failure-to-protect claims In Hale v. Tallapoosa County, the Eleventh Circuit held that to survive summary judgment on an Eighth Amendment failure-to-protect claim a plaintiff must produce sufficient evidence of (1) a substantial risk of serious harm, (2) the defendants' deliberate indifference to that risk, and (3) causation. Date: 1995-05-02 Tags: legal,violence Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Fulton County Jail consent decree entered January 3, 2025 On January 3, 2025, DOJ's Civil Rights Division and the U.S. Attorney's Office for the Northern District of Georgia agreed to a proposed consent decree with Fulton County and the Fulton County Sheriff, which a federal judge approved and entered as a court order, addressing DOJ's finding that conditions inside the Fulton County Jail violate the constitutional and federal statutory rights of incarcerated people. Date: 2025-01-03 Tags: legal,conditions Sources: Fulton County Jail Reform - [confirmed] Rhodes v. Chapman: harsh conditions are part of the penalty The Court stated that conditions of confinement, other than those at issue in Estelle v. Gamble and Hutto v. Finney, alone or in combination, may deprive inmates of the minimal civilized measure of life's necessities and could be cruel and unusual under the contemporary standard of decency, but conditions that cannot be said to be cruel and unusual under contemporary standards are not unconstitutional, and to the extent such conditions are restrictive and even harsh, they are part of the penalty that criminal offenders pay for their offenses against society. Tags: legal,conditions Sources: Rhodes v. Chapman - [confirmed] Brooks v. Warden: strong likelihood of injury required, not mere possibility In Brooks v. Warden, the Eleventh Circuit stated that there must be a 'strong likelihood' of injury, 'rather than a mere possibility,' before an official's failure to act can constitute deliberate indifference. Date: 2015-09-03 Tags: legal,conditions Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Legislative history of § 3626 Section 3626 was added by Pub. L. 103-322, title II, section 20409(a), Sept. 13, 1994, 108 Stat. 1827, and was amended by Pub. L. 104-134, title I, section 101[(a)] [title VIII, section 802(a)], Apr. 26, 1996, 110 Stat. 1321, 1321-66, and by Pub. L. 105-119, title I, section 123(a), Nov. 26, 1997, 111 Stat. 2470. Tags: legal,legislation Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Swain v. Junior: habeas release decision not before the Eleventh Circuit In Swain v. Junior, the Eleventh Circuit noted that the district court separately denied the plaintiffs relief on their habeas corpus petition seeking release of inmates, and that decision was not before the court of appeals on this appeal. Date: 2020-06-15 Tags: legal Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] LaMarca v. Turner: injunction on protective confinement vacated In LaMarca v. Turner, the Eleventh Circuit vacated the district court's injunction regarding conditions in protective confinement and remanded for the district court to determine whether an injunction was necessary to ensure continuance of currently constitutional conditions, because those conditions, taken singularly or together, did not constitute cruel and unusual punishment and did not ensure the prior infirm conditions would not recur. Date: 1993-01-01 Tags: legal,conditions,solitary Sources: 995 F.2d 1526 (1993) - [confirmed] Turner v. Burnside: step one of exhaustion analysis The first step of the Turner two-step process requires the court to take the plaintiff's version of disputed facts as true and dismiss if that version shows a failure to exhaust. Date: 2008-08-28 Tags: legal Sources: Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener) - [confirmed] 1996 amendment replaced prison-crowding remedies with prison-conditions remedies The Amendments note to 18 U.S.C. § 3626 states that the 1996 amendment by Pub. L. 104-134 amended the section generally, substituting provisions relating to appropriate remedies with respect to prison conditions for former provisions relating to appropriate remedies with respect to prison crowding. Date: 1996-01-01 Tags: legal,legislation Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Rhodes v. Chapman: conditions may deprive inmates of minimal civilized measure of life's necessities The Rhodes v. Chapman majority stated that conditions, alone or in combination, may deprive inmates of 'the minimal civilized measure of life's necessities,' and such conditions could be cruel and unusual under the contemporary standard of decency. Date: 1981-06-15 Tags: legal,conditions Sources: Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener) - [confirmed] Prisoner release orders only by three-judge court 18 U.S.C. § 3626 provides that in any federal civil action with respect to prison conditions, a prisoner release order shall be entered only by a three-judge court in accordance with 28 U.S.C. § 2284, if the requirements of subparagraph (E) have been met. Tags: legal,policy Sources: 18 USC 3626: Appropriate remedies with respect to prison conditions - [confirmed] Farmer v. Brennan: injunctive-relief deliberate indifference judged at time suit brought and thereafter In Farmer v. Brennan, the Court stated that in a suit seeking injunctive relief to prevent a substantial risk of serious injury from ripening into actual harm, the subjective factor of deliberate indifference should be determined in light of the prison authorities' current attitudes and conduct, their attitudes and conduct at the time suit is brought and persisting thereafter. Date: 1994-01-01 Tags: legal Sources: Farmer v. Brennan, 511 U.S. 825 (1994). - [confirmed] Dukes common contention standard Dukes requires that plaintiffs' claims 'must depend upon a common contention' such that 'determination of [their] truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke.' Tags: legal Sources: Victor Parsons v. Charles Ryan, U.S. Court of Appeals, 9th Circuit, 2014-06-05 (court record via CourtListener) - [reported] Sixth Circuit: Hutto v. Finney and States' Eleventh Amendment immunity In Donald Freed v. Michelle Thomas (6th Cir., 2025-05-12), the court followed Hutto v. Finney, 437 U.S. 678, 695 (1978), regarding "the States' Eleventh Amendment immunity." Date: 2025-05-12 Tags: legal Sources: Donald Freed v. Michelle Thomas, Court of Appeals for the Sixth Circuit, 2025-05-12 (court record via CourtListener) - [confirmed] Harris v. Thigpen: inadequate staffing may rise to deliberate indifference LaMarca v. Turner states that the Eleventh Circuit, in Harris v. Thigpen, 941 F.2d 1495, 1505 (11th Cir. 1991), suggested that inadequate staffing may rise to deliberate indifference as to prisoner safety (citing Ramos v. Lamm, 639 F.2d 559, 575 (10th Cir. 1980)). Date: 1991-01-01 Tags: staffing,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Guthrie v. Evans filed September 1972 over Reidsville conditions Guthrie v. Evans was filed in September 1972 by inmates of Georgia State Prison at Reidsville, alleging racial segregation and unconstitutional practices and conditions of confinement at the state's main maximum-security facility. Date: 1972-09-01 Tags: legal,conditions,facilities Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Williams v. Edwards: Angola conditions 'shock the conscience' In Williams v. Edwards, the district court found that conditions at the Louisiana State Penitentiary at Angola 'shock the conscience of any right thinking person' and 'flagrantly violate basic constitutional requirements as well as applicable State laws,' and that state authorities were 'either failing or refusing to take the necessary steps to correct these conditions.' Date: 1977-03-15 Tags: conditions,legal,facilities Sources: Hayes Williams v. Edwin Edwards, Governor of the State of Louisiana, Defendants, U.S. Court of Appeals, 5th Circuit, 1977-03-15 (court record via CourtListener) - [confirmed] Cason v. Seckinger: § 3626(b)(3) requires provision-by-provision findings Cason v. Seckinger holds that § 3626(b)(3) requires particularized, provision-by-provision findings that each requirement imposed by a consent decree satisfies the need-narrowness-intrusiveness criteria given the nature of the current and ongoing violation, and that a conclusory statement the relief 'extends no further than necessary' is insufficient. Date: 2000-10-24 Tags: legal,policy Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Plaintiff need not show official knew precisely who would attack whom In Hale v. Tallapoosa County, the court held that a plaintiff need not show the official knew precisely who would attack whom, only that the official had subjective knowledge of a generalized, substantial risk of serious harm from inmate violence. Date: 1995-05-02 Tags: legal,violence Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Fulton County Jail findings announced November 14, 2024 On November 14, 2024, DOJ's Civil Rights Division and the U.S. Attorney's Office for the Northern District of Georgia announced findings from an investigation of the Fulton County Jail, concluding that conditions inside the Jail violate the constitutional and federal statutory rights of incarcerated people. Date: 2024-11-14 Tags: legal,conditions Sources: Fulton County Jail Investigation Findings - [confirmed] Rhodes v. Chapman: five considerations held insufficient The District Court in Rhodes v. Chapman relied on five considerations, including that inmates at SOCF were serving long terms of imprisonment, that SOCF housed 38% more inmates than its design capacity, and that studies recommended each inmate have at least 50-55 square feet of living quarters; the Supreme Court held these considerations insufficient to support a constitutional violation. Tags: legal,conditions,facilities Sources: Rhodes v. Chapman - [reported] Grochowski v. Clayton County followed Hamm v. DeKalb County Later treatment: Grochowski v. Clayton County, F.3d 11th Cir followed Hamm v. DeKalb County, F.2d 11th Cir, with claims arising under the Fourteenth Amendment's Due Process Clause. Date: 2020-06-22 Tags: legal,conditions Sources: Donald Grochowski v. Clayton County, Georgia, Court of Appeals for the Eleventh Circuit, 2020-06-22 (court record via CourtListener) - [confirmed] Brooks v. Warden: simultaneous cell-door opening was mere possibility, not strong likelihood In Brooks v. Warden, the Eleventh Circuit held that the plaintiff's allegation that his and his attacker's cell doors would open simultaneously during a situation preventing immediate intervention by guards was a mere possibility, not enough to plausibly allege a strong likelihood of serious injury. Date: 2015-09-03 Tags: legal,violence,conditions Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] 1997 amendment to § 3626 applies to pending cases Pub. L. 105-119, title I, § 123(b), Nov. 26, 1997, 111 Stat. 2471, provided that the amendments made by that section shall take effect upon the date of enactment (Nov. 26, 1997) and shall apply to pending cases. Date: 1997-01-01 Tags: legal,legislation Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Lane v. Philbin: three components of deliberate indifference In Lane v. Philbin, the Eleventh Circuit stated that the second element of an Eighth Amendment claim, the defendants' deliberate indifference to a substantial risk of serious harm, has three components: (1) subjective knowledge of a risk of serious harm; (2) disregard of that risk; (3) by conduct that is more than mere negligence. Date: 2016-08-26 Tags: legal,conditions Sources: Rodney Manyon Lane v. Ted Philbin, U.S. Court of Appeals, 11th Circuit, 2016-08-26 (court record via CourtListener) - [confirmed] LaMarca v. Turner: mixed outcome on violence and rape at Glades CI In an Eighth Amendment suit over inmate violence and rape at Glades Correctional Institution, the Eleventh Circuit found the evidence supported an unconstitutional risk of violence and causation, but required reconsideration of the superintendent's knowledge at the time of each incident, vacated the new plaintiffs' damages awards for jury trial, affirmed the injunction in part (rape-victim treatment and training) and remanded parts that intruded too far or targeted conditions no longer unconstitutional, and vacated fees. Date: 1993-01-01 Tags: legal,violence,conditions Sources: 995 F.2d 1526 (1993) - [confirmed] Turner v. Burnside: two-step exhaustion procedure The Eleventh Circuit adopted a two-step process for PLRA exhaustion motions: first take the plaintiff's version of disputed facts as true and decide if dismissal is warranted; if not, the court makes specific findings to resolve disputed facts. Date: 2008-08-28 Tags: legal Sources: Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener) - [confirmed] 1997 amendment changed 'current or ongoing' to 'current and ongoing' The Amendments note to 18 U.S.C. § 3626 states that the 1997 amendment by Pub. L. 105-119, § 123(a)(2), substituted 'current and ongoing' for 'current or ongoing' in subsection (b)(3), and that § 123(a)(3)(C) added paragraphs (3) and (4) of subsection (e). Date: 1997-01-01 Tags: legal,legislation Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Rhodes v. Chapman: restrictive and harsh conditions are part of the penalty, not unconstitutional per se The Rhodes v. Chapman majority stated that conditions that are restrictive and even harsh are not unconstitutional, but are part of the penalty criminal offenders pay for their offenses against society. Date: 1981-06-15 Tags: legal,conditions Sources: Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener) - [confirmed] Prior less-intrusive relief required before prisoner release order 18 U.S.C. § 3626 provides that no court shall enter a prisoner release order unless a court has previously entered an order for less intrusive relief that failed to remedy the deprivation of the federal right, and the defendant has had a reasonable amount of time to comply with the previous court orders. Tags: legal,policy Sources: 18 USC 3626: Appropriate remedies with respect to prison conditions - [confirmed] Farmer v. Brennan: prison officials have duty to protect prisoners from violence by other prisoners In Farmer v. Brennan, the Court stated that, as the lower courts have uniformly held and the Court has assumed, prison officials have a duty to protect prisoners from violence at the hands of other prisoners. Date: 1994-01-01 Tags: legal,violence Sources: Farmer v. Brennan, 511 U.S. 825 (1994). - [confirmed] Braggs v. Dunn: objective and subjective tests for deliberate indifference In Braggs v. Dunn, the court stated the objective test for an Eighth Amendment deliberate-indifference claim requires showing the prisoner has serious medical needs and either has already been harmed or been incarcerated under conditions posing a substantial risk of serious harm, while the subjective test requires showing the official knew of and disregarded an excessive risk to inmate health or safety. Date: 2017-01-01 Tags: legal,medical,mental_health Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [confirmed] Parsons v. Ryan: statewide policies expose inmates to substantial risk In Parsons v. Ryan, the Ninth Circuit described the certified Arizona classes as challenging numerous policies and practices of statewide application governing medical care, dental care, mental health care, and conditions of confinement in isolation cells that expose inmates to a substantial risk of serious harm to which the defendants are deliberately indifferent. Date: 2014-01-01 Tags: legal,medical,mental_health,solitary Sources: Victor Parsons v. Charles Ryan, U.S. Court of Appeals, 9th Circuit, 2014-06-05 (court record via CourtListener) - [confirmed] LaMarca v. Turner: management problems affected prison security In LaMarca v. Turner, the Eleventh Circuit held that among the management problems during the superintendent's tenure were low morale among the prison's staff, high employee turnover leading to a less experienced staff, high vacancy rates for staff positions, and inadequate supervision of employees, which had a direct effect on the prison's ability to maintain security. Date: 1993-07-07 Tags: staffing,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Guthrie class certified 1973; desegregation ordered April 1974 An amended complaint was filed and the class certified in 1973 in Guthrie v. Evans, and Georgia State Prison was ordered desegregated in April 1974. Tags: legal,conditions,facilities Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Cason v. Seckinger: 'current and ongoing' violation defined Cason v. Seckinger holds that a 'current and ongoing' violation under § 3626(b)(3) means a violation that exists at the time the district court conducts the inquiry, not a potential future violation. Date: 2000-10-24 Tags: legal Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Rhodes v. Chapman: 50-55 square feet per inmate recommendation In Rhodes v. Chapman, several studies recommended that each inmate have at least 50-55 square feet of living quarters; the Supreme Court held this recommendation insufficient to support a constitutional violation. Tags: legal,conditions,facilities Sources: Rhodes v. Chapman - [reported] Boyd v. Nichols followed Purcell v. Toombs County Later treatment: Boyd v. Nichols, F. Supp. 2d M.D. Ga followed Purcell v. Toombs County, F.3d 11th Cir; the court noted no expert testified that the jail, given its inmate capacity, was understaffed, and without evidence of inadequate staffing the staffing claim failed on summary judgment. Date: 2009-05-05 Tags: legal,staffing,conditions Sources: Boyd v. Nichols, District Court, M.D. Georgia, 2009-05-05 (court record via CourtListener) - [confirmed] Brooks v. Warden: failure-to-protect claim dismissed, sanitation claim reversed On appeal from a dismissal for failure to state a claim, the Eleventh Circuit affirmed dismissal of the failure-to-protect claim (no plausible substantial risk before the riot) but reversed on the hospital sanitation claim: being forced to sit in his own feces for two days stated an Eighth Amendment claim, the deputy warden lacked qualified immunity, and the PLRA physical-injury bar does not prevent nominal damages. Date: 2015-09-03 Tags: legal,conditions,violence Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Exhaustion requirement under 42 U.S.C. § 1997e 42 U.S.C. § 1997e provides that no action shall be brought with respect to prison conditions under section 1983 of title 42, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] Lane v. Philbin: Eleventh Circuit reversed dismissal of failure-to-protect claim In Lane v. Philbin, the Eleventh Circuit reversed dismissal of an Eighth Amendment failure-to-protect claim, holding that the complaint's allegations sufficed to make out a plausible claim that the defendant prison officials were aware of the serious risk of harm faced by the plaintiff at Valdosta State Prison. Date: 2016-08-26 Tags: legal,violence,conditions Sources: Rodney Manyon Lane v. Ted Philbin, U.S. Court of Appeals, 11th Circuit, 2016-08-26 (court record via CourtListener) - [confirmed] PLRA requires injunctive relief be narrowly drawn (Thomas v. Bryant) In Thomas v. Bryant, the Eleventh Circuit stated that the PLRA only permits the entry of injunctive relief that is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right. Date: 2009-01-01 Tags: legal,policy Sources: media.ca11.uscourts.gov: 200911658 - [confirmed] Jones v. Bock: exhaustion is an affirmative defense In Jones v. Bock, the Supreme Court held that failure to exhaust is an affirmative defense under the PLRA, and inmates are not required to specially plead or demonstrate exhaustion in their complaints. Tags: legal Sources: Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener) - [confirmed] Prisoner release order requires prior less-intrusive relief to have failed 18 U.S.C. § 3626 provides that no court shall enter a prisoner release order unless a court has previously entered an order for less intrusive relief that failed to remedy the deprivation of the Federal right, and the defendant has had a reasonable amount of time to comply with the previous court orders. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] Rhodes v. Chapman concurrence: totality of circumstances required Justice Brennan, concurring in the judgment in Rhodes v. Chapman (joined by Justices Blackmun and Stevens), wrote that a court considering an Eighth Amendment challenge to conditions of confinement must examine the totality of the circumstances. Date: 1981-06-15 Tags: legal,conditions Sources: Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener) - [confirmed] Prospective relief terminable on motion after two years 18 U.S.C. § 3626 provides that prospective relief in a prison-conditions civil action is terminable upon motion of any party or intervener 2 years after the date the court granted or approved the prospective relief, or 1 year after the court entered an order denying termination of prospective relief. Tags: legal,policy Sources: 18 USC 3626: Appropriate remedies with respect to prison conditions - [confirmed] Hudson v. McMillian: extreme deprivations required for conditions-of-confinement claims In Hudson v. McMillian, the Court stated that extreme deprivations are required to make out a conditions-of-confinement claim, because routine discomfort is part of the penalty that criminal offenders pay for their offenses against society, whereas in the excessive force context society's expectations are different. Tags: legal,conditions Sources: Keith J. HUDSON, Petitioner, v. Jack McMILLIAN et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Wade v. McDade (en banc) governs Eleventh Circuit deliberate-indifference state of mind The Eleventh Circuit (Chapman v. Dunn, 2025; Wingo v. Harris, 2025; Stalley v. Lake CI Warden, 2024) applied Wade v. McDade, 106 F.4th 1251 (11th Cir. 2024) (en banc) on the defendants' state of mind and the 'risk of serious harm' standard. Tags: legal,conditions Sources: Michael Chapman v. Jefferson Dunn, Court of Appeals for the Eleventh Circuit, 2025-02-25 (court record via CourtListener); Tiffany Wingo v. Major Branson Harris, Court of Appeals for the Eleventh Circuit, 2025-12-01 (court record via CourtListener); Douglas Stalley v. Lake CI Warden, Court of Appeals for the Eleventh Circuit, 2024-12-30 (court record via CourtListener) - [confirmed] Lewis v. Casey: systemic challenge requires widespread actual injury In Lewis v. Casey, the Supreme Court held that the success of the inmates' systemic challenge was dependent on their ability to show widespread actual injury, and the District Court's failure to identify anything more than isolated instances of actual injury rendered its finding of a systemic Bounds violation invalid. Tags: legal Sources: law.cornell.edu: 343 - [confirmed] LaMarca v. Turner: three elements for Eighth Amendment damages In LaMarca v. Turner, the Eleventh Circuit held that a prisoner-plaintiff seeking Eighth Amendment damages must prove three elements: (1) a condition of confinement that inflicted unnecessary pain or suffering, (2) the defendant's deliberate indifference to that condition, and (3) causation. Date: 1993-07-07 Tags: legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Guthrie conditions trial before Special Master, July 1976 to July 1977 The conditions issues in Guthrie v. Evans went to trial before a Special Master beginning in July 1976; the trial continued for 5 months over a one-year period ending in July 1977, covering substandard environmental conditions, inadequate medical and psychiatric care, unconstitutional discipline, guard brutality, failure to protect from harm, racial discrimination, and related claims. Tags: legal,conditions,medical,violence Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Harrison v. Culliver: 'constant threat of violence' standard Harrison v. Culliver, 746 F.3d 1288, 1300 (11th Cir. 2014), characterized the risk in that case as a 'constant threat of violence'; however, proof of 'pervasive' violence is not necessary to make out a substantial risk of harm. Date: 2021-10-06 Tags: violence,legal Sources: ANTONIO LACY v. JOHN COUGHLIN & another., Massachusetts Appeals Court, 2021-10-06 (court record via CourtListener) - [confirmed] Cason v. Seckinger: fourteen consent decrees entered 1990-1996 The Cason v. Seckinger case was resolved by entry of fourteen consent decrees entered beginning in 1990 and ending in 1996, three of which contained provisions for automatic termination. Tags: legal,policy Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Hale reversed summary judgment for sheriff and county In Hale v. Tallapoosa County, the Eleventh Circuit reversed summary judgment for the sheriff and county, holding that evidence of regular inmate-on-inmate violence during jail overcrowding, sometimes requiring medical attention or hospitalization, was sufficient for a jury to find a substantial risk of serious harm. Date: 1995-05-02 Tags: legal,violence Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Conditions claims require culpable state of mind The Supreme Court held that a prisoner claiming that the conditions of his confinement violate the Eighth Amendment must show a culpable state of mind on the part of prison officials, citing Whitley v. Albers and distinguishing Rhodes v. Chapman. Date: 1990-01-01 Tags: legal,conditions Sources: October Term, 1990 - [reported] Benning v. Commissioner, GDC followed Thomas v. Bryant Later treatment: Ralph Harrison Benning v. Commissioner, Georgia Department of Corrections, F.4th 11th Cir followed Thomas v. Bryant, F.3d 11th Cir, citing 18 U.S.C. § 3626(a)(1)(A). Date: 2023-06-23 Tags: legal,conditions Sources: Ralph Harrison Benning v. Commissioner, Georgia Department of Corrections, Court of Appeals for the Eleventh Circuit, 2023-06-23 (court record via CourtListener) - [confirmed] Goodman v. Kimbrough: dereliction of duty affirmed despite concern In Goodman v. Kimbrough, the Eleventh Circuit affirmed summary judgment for jail officers despite finding their dereliction of duty concerning, stating that the law compelled that result. Date: 2013-06-21 Tags: legal,conditions,staffing Sources: Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener) - [confirmed] Sua sponte dismissal of frivolous prison-conditions actions 42 U.S.C. § 1997e provides that the court shall on its own motion or on the motion of a party dismiss any action brought with respect to prison conditions under section 1983 of title 42, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility if the court is satisfied that the action is frivolous, malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief from a defendant who is immune from such relief. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] Lane v. Philbin: officials cannot escape liability because inmate did not report threats Lane v. Philbin states that prison officials may not escape liability just because an injured inmate did not inform anyone that he was being threatened or that he faced an attack from another inmate, citing Hale v. Tallapoosa County. Date: 2016-08-26 Tags: legal,violence Sources: Rodney Manyon Lane v. Ted Philbin, U.S. Court of Appeals, 11th Circuit, 2016-08-26 (court record via CourtListener) - [confirmed] Thomas v. Bryant: district court did not abuse discretion in narrow injunction In Thomas v. Bryant, the Eleventh Circuit held that the district court was keenly aware of the PLRA's narrowness requirements and seemingly fashioned a narrow injunction targeting the violation of McKinney's constitutional rights in a most non-intrusive manner, and could not conclude the district court abused its discretion in fashioning the injunctive relief. Date: 2009-01-01 Tags: legal,policy Sources: media.ca11.uscourts.gov: 200911658 - [confirmed] Immediate termination of prospective relief lacking narrow-drawing findings 18 U.S.C. § 3626 provides that in any civil action with respect to prison conditions, a defendant or intervener is entitled to immediate termination of any prospective relief approved or granted without a court finding that the relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] Wilson v. Seiter: subjective culpable state of mind required for conditions claims In Wilson v. Seiter, the Supreme Court held that a prisoner claiming that prison conditions constitute cruel and unusual punishment must show a subjective culpable state of mind on the part of prison officials, such as deliberate indifference, and that there is no significant distinction between claims alleging inadequate medical care and those alleging inadequate conditions of confinement for this purpose. Date: 1991-06-17 Tags: legal,conditions,medical Sources: Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener) - [confirmed] Prospective relief survives termination if ongoing violation found 18 U.S.C. § 3626 provides that prospective relief shall not terminate if the court makes written findings based on the record that the relief remains necessary to correct a current and ongoing violation of a federal right, extends no further than necessary, and is narrowly drawn and the least intrusive means to correct the violation. Tags: legal,policy Sources: 18 USC 3626: Appropriate remedies with respect to prison conditions - [confirmed] Hope v. Pelzer: qualified immunity precluded at summary judgment for hitching-post guards In Hope v. Pelzer, the Supreme Court held that the defense of qualified immunity was precluded at the summary judgment phase for prison guards who handcuffed an inmate to a hitching post. Tags: legal,conditions Sources: law.cornell.edu: 730 - [confirmed] Braggs v. Dunn: Phase 2A class of prisoners with serious mental illness certified In Braggs v. Dunn, the district court certified a Phase 2A plaintiff class consisting of all persons with a serious mental illness who are, or will be, confined within ADOC facilities, excluding Tutwiler Prison for Women and the work-release centers. Date: 2017-01-01 Tags: legal,mental_health Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [confirmed] Marbury v. Warden: isolated attacks may establish substantial risk of serious harm The Eleventh Circuit (Marbury v. Warden, 2026; Wingo v. Harris, 2025) applied Marbury v. Warden, 936 F.3d 1227, 1233 (11th Cir. 2019), noting that 'occasional, isolated attacks by one prisoner on another' can suffice to establish a substantial risk of serious harm, and citing Lane v. Philbin, 835 F.3d 1307, and Harrison v. Culliver, 746 F.3d 1299-1300. Tags: legal,violence,conditions Sources: Mitchell Marbury v. Warden III, Court of Appeals for the Eleventh Circuit, 2026-07-07 (court record via CourtListener); In Re: Blue Cross Blue Shield Antitrust Litigation, Court of Appeals for the Eleventh Circuit, 2023-10-25 (court record via CourtListener); Tiffany Wingo v. Major Branson Harris, Court of Appeals for the Eleventh Circuit, 2025-12-01 (court record via CourtListener) - [confirmed] Lewis v. Casey: remedy limited to inadequacy producing injury In Lewis v. Casey, the Court held that the remedy for a constitutional violation must be limited to the inadequacy that produced the injury-in-fact that the plaintiff has established, and that this rule applies equally in a class action because even named plaintiffs in a class action must show that they personally have been injured. Tags: legal Sources: law.cornell.edu: 343 - [confirmed] LaMarca v. Turner: evidence supported unconstitutional risk of violence In LaMarca v. Turner, the Eleventh Circuit found the evidence supported a finding of an unconstitutional risk of violence at the Florida prison. Date: 1993-07-07 Tags: violence,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Three Guthrie consent decrees signed in 1978 Three consent decrees resolved the Guthrie v. Evans conditions issues in 1978: the first on July 19, a second more comprehensive decree on August 4, and a final decree on December 1 resolving all remaining issues except medical and psychiatric care and racial discrimination in discipline. Date: 1978-01-01 Tags: legal,conditions,medical Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Courts have rejected Eighth Amendment claims in weapon-attack cases as matter of law There is a long list of cases involving inmate-on-inmate attacks using weapons fashioned from prison objects where courts have rejected Eighth Amendment claims as a matter of law, including Lakin, 758 F.3d at 67-69 (padlock) and Harrison v. Culliver, 746 F.3d 1288, 1299-1300 (11th Cir. 2014) (box cutter). Date: 2021-10-06 Tags: violence,legal Sources: ANTONIO LACY v. JOHN COUGHLIN & another., Massachusetts Appeals Court, 2021-10-06 (court record via CourtListener) - [confirmed] Cason v. Seckinger: allegations of pervasive sexual abuse and harassment of female inmates by staff The Cason v. Seckinger lawsuit claimed that prison conditions were unconstitutional because of alleged pervasive sexual abuse of female inmates by staff and pervasive sexual harassment of female inmates by staff. Tags: violence,staffing,legal,conditions Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Hale: available but unused measures supported deliberate indifference finding In Hale v. Tallapoosa County, the Eleventh Circuit held that evidence the sheriff knew of ways to reduce the risk of inmate violence -- classifying and segregating inmates by violence propensity, assigning inmates to cells/bunks, training jailers, and adequately supervising and monitoring inmates -- but did not pursue them was sufficient for a jury to find deliberate indifference. Date: 1995-05-02 Tags: legal,violence,staffing Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Conditions may violate Eighth Amendment only in combination for a single human need The Court explained that some conditions of confinement may establish an Eighth Amendment violation in combination when each would not do so alone, but only when they have a mutually enforcing effect that produces the deprivation of a single, identifiable human need such as food, warmth, or exercise, for example a low cell temperature at night combined with a failure to issue blankets; nothing so amorphous as overall conditions can rise to the level of cruel and unusual punishment when no specific deprivation of a single human need exists. Date: 1990-01-01 Tags: legal,conditions Sources: October Term, 1990 - [confirmed] PLRA § 3626(a)(1)(A) limits on prospective relief Under 18 U.S.C. 3626(a)(1)(A), the court shall not grant or approve any prospective relief in a civil action with respect to prison conditions unless the court finds that such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right, and the court shall give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the relief. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Goodman v. Kimbrough: failed cell checks and deactivated call button were negligence, not deliberate indifference In Goodman v. Kimbrough, the Eleventh Circuit held that the failure to conduct required cell checks and head counts, and the deactivation of an emergency call button, was evidence of negligence or gross negligence, but not evidence that officers subjectively knew the plaintiff was in danger and deliberately disregarded the risk, because the deliberate indifference standard requires more than showing officials should have known. Date: 2013-06-21 Tags: legal,conditions,staffing Sources: Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener) - [confirmed] Attorney's fees limits for prisoner actions under § 1997e 42 U.S.C. § 1997e provides that in any action brought by a prisoner confined to any jail, prison, or other correctional facility, in which attorney's fees are authorized under section 1988 of title 42, such fees shall not be awarded except to the extent that the fee was directly and reasonably incurred in proving an actual violation of the plaintiff's rights protected by a statute pursuant to which a fee may be awarded under section 1988, and the amount of the fee is proportionately related to the court ordered relief for the violation, or the fee was directly and reasonably incurred in enforcing the relief ordered for the violation. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] 42 U.S.C. § 1997c(a): definition of egregious or flagrant conditions 42 U.S.C. § 1997c(a) describes 'egregious or flagrant conditions which deprive persons residing in institutions of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States causing them to suffer grievous harm.' Tags: legal,policy Sources: law.cornell.edu: 1997c - [confirmed] Thomas v. Bryant: deliberate indifference to mentally ill inmate via chemical agents After a bench trial, the Eleventh Circuit affirmed the declaratory judgment and permanent injunction. It held that the district court did not clearly err in finding that Florida DOC officials were deliberately indifferent when they repeatedly used chemical agents on a mentally ill inmate in violation of the Eighth Amendment (conditions of confinement). It also held the district court did not abuse its discretion in shaping the injunction, which the defendants attacked only in conclusory terms; their unraised PLRA-findings arguments were abandoned. Date: 2009-01-01 Tags: legal,mental_health,conditions Sources: media.ca11.uscourts.gov: 200911658 - [confirmed] McKinnon: transfer or release moots individual injunctive claim The general rule in the Eleventh Circuit is that a prisoner's transfer or release from a jail moots his individual claim for declaratory and injunctive relief, and if the class has not yet been certified, that mootness also justifies dismissal of the entire class action. Date: 1984-11-05 Tags: legal,transfers Sources: McKinnon v. Talladega County, U.S. Court of Appeals, 11th Circuit, 1984-11-05 (court record via CourtListener) - [confirmed] Automatic stay postponement limited to 60 days for good cause 18 U.S.C. § 3626 provides that the court may postpone the effective date of an automatic stay under subsection (e)(2)(A) for not more than 60 days for good cause, and no postponement is permissible because of general congestion of the court's calendar. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] Wilson v. Seiter concurrence: deliberate-indifference requirement inconsistent with precedent Justice White, concurring in the judgment in Wilson v. Seiter (joined by Justices Marshall, Blackmun, and Stevens), stated that the majority's deliberate-indifference requirement is inconsistent with the Court's prior decisions, so he concurred only in the judgment. Date: 1991-06-17 Tags: legal,conditions Sources: Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener) - [confirmed] Hope v. Pelzer: obvious cruelty of hitching-post practice gave notice of constitutional violation In Hope v. Pelzer, the Court stated that the obvious cruelty inherent in the hitching-post practice should have provided the respondents with some notice that their alleged conduct violated Hope's constitutional protection against cruel and unusual punishment. Tags: legal,conditions Sources: law.cornell.edu: 730 - [confirmed] Braggs v. Dunn: liability opinion addressed mental-health and correctional understaffing In Braggs v. Dunn, the court's liability opinion included separate subsections addressing Mental-Health Understaffing and Correctional Understaffing as part of the factual background supporting the Eighth Amendment violation. Date: 2017-01-01 Tags: legal,staffing,mental_health Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [confirmed] Lewis v. Casey: systemwide relief requires proof violations pervaded system The Lewis v. Casey majority stated that its holding on the inappropriateness of systemwide relief for illiterate inmates rests on the respondents' failure to prove that denials of access to illiterate prisoners pervaded the State's prison system, not on standing rules. Tags: legal Sources: law.cornell.edu: 343 - [confirmed] LaMarca v. Turner: lack of officer supervision as evidentiary basis In LaMarca v. Turner, the Eleventh Circuit's evidentiary basis for the Eighth Amendment violation included a lack of supervision of officers. Date: 1993-07-07 Tags: staffing,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Special Monitor appointed June 1979 in Guthrie By Orders of Reference dated June 1 and June 20, 1979, the Guthrie v. Evans court appointed a Special Monitor to assess compliance with the consent decrees, a device previously approved by the Fifth Circuit in Newman v. Alabama. Date: 1979-06-01 Tags: legal,conditions Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Turner v. Burnside: remedies rational inmates cannot be expected to use are unavailable Turner v. Burnside, 541 F.3d 1077, 1084 (11th Cir. 2008), held that 'Remedies that rational inmates cannot be expected to use are not capable of accomplishing their purposes and so are not available,' cited with approval in Ross, 136 S.Ct. at 1859-1860. Date: 2019-06-03 Tags: legal,policy Sources: Davis v. Commonwealth, Massachusetts Appeals Court, 2019-06-03 (court record via CourtListener) - [confirmed] Cason v. Seckinger: GDC moved to terminate consent decrees under PLRA on November 12, 1998 On November 12, 1998, the GDC defendants in Cason v. Seckinger filed a motion to vacate and terminate all remaining consent decrees pursuant to the Prison Litigation Reform Act, 18 U.S.C. § 3626. Date: 1998-11-12 Tags: legal,policy Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] LaMarca causation standard for prison-condition Eighth Amendment claims In LaMarca v. Turner, the Eleventh Circuit held that a finding that a prison condition offends the Eighth Amendment presupposes the distinct likelihood that the harm threatened will result, and that the evidence permits a finding of a causal link between the objectively intolerable conditions and the plaintiffs' injuries. Date: 1995-05-02 Tags: legal,conditions Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Overall conditions alone cannot establish Eighth Amendment violation The Court stated that nothing so amorphous as overall conditions can rise to the level of cruel and unusual punishment when no specific deprivation of a single human need exists. Date: 1990-01-01 Tags: legal,conditions Sources: October Term, 1990 - [confirmed] PLRA § 3626(a)(2) limits on preliminary injunctive relief Under 18 U.S.C. 3626(a)(2), preliminary injunctive relief in a civil action with respect to prison conditions must be narrowly drawn, extend no further than necessary to correct the harm the court finds requires preliminary relief, and be the least intrusive means necessary to correct that harm; the court must give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the preliminary relief; and preliminary injunctive relief shall automatically expire 90 days after its entry unless the court makes the findings required under subsection (a)(1) for the entry of prospective relief and makes the order final before the expiration of the 90-day period. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Goodman v. Kimbrough: subjective knowledge and disregard required, more than gross negligence In Goodman v. Kimbrough, the Eleventh Circuit stated that to prove deliberate indifference, Goodman had to prove subjective knowledge of a risk of serious harm and disregard of that risk, by conduct that is more than gross negligence. Date: 2013-06-21 Tags: legal,conditions Sources: Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener) - [confirmed] Judgment offset for attorney's fees under § 1997e 42 U.S.C. § 1997e provides that whenever a monetary judgment is awarded in such an action, a portion of the judgment not to exceed 25 percent shall be applied to satisfy the amount of attorney's fees awarded against the defendant, and if the award of attorney's fees is not greater than 150 percent of the judgment, the excess shall be paid by the defendant. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] 42 U.S.C. § 1997c: 90-day bar on Attorney General intervention motion 42 U.S.C. § 1997c bars the Attorney General from filing a motion to intervene before 90 days after the commencement of the action, unless the court determines it would be in the interests of justice to shorten or waive the time period. Tags: legal,policy Sources: law.cornell.edu: 1997c - [confirmed] PLRA preliminary injunctive relief must be narrow and expires in 90 days Section 3626(a) of title 18 provides that preliminary injunctive relief in a prison-conditions case must be narrowly drawn, extend no further than necessary to correct the harm, and be the least intrusive means necessary to correct that harm, that the court shall give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the preliminary relief, and that such relief shall automatically expire on the date that is ninety days after its entry unless the court makes the findings required for prospective relief and makes the order final before the expiration of the ninety-day period. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] PLRA requires substantial weight to public-safety impact of relief 18 U.S.C. § 3626 requires the court to give substantial weight to any adverse impact on public safety or on the operation of a criminal justice system caused by the relief. The document notes this is the statutory source of Brown v. Plata's 'substantial weight' language, and that the statute says 'narrowly drawn' while 'narrowly tailored' is Plata's paraphrase. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] Wal-Mart v. Dukes applied to class certification in prison/detention cases The Ninth Circuit (S.D. v. Reese, 2026) and Fifth Circuit (Hamm v. Ochsner-Acadia, 2026) applied Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) to class-certification and predominance questions, relevant to systemic prison-conditions class actions. Tags: legal,policy Sources: S.D. v. Reese, Court of Appeals for the Ninth Circuit, 2026-09-17 (court record via CourtListener); Hamm v. Ochsner-Acadia, Court of Appeals for the Fifth Circuit, 2026-08-19 (court record via CourtListener) - [confirmed] Lewis v. Casey: systemwide relief unrelated to class-action law The Lewis v. Casey majority stated that the issue of systemwide relief has nothing to do with class-action law: however extensive a class may be, unless violations as to that class were shown to occur in all institutions of the State's system, systemwide relief was not justified. Tags: legal Sources: law.cornell.edu: 343 - [confirmed] LaMarca v. Turner: lack of adequate patrols as evidentiary basis In LaMarca v. Turner, the Eleventh Circuit's evidentiary basis for the Eighth Amendment violation included the lack of adequate patrols at the prison. Date: 1993-07-07 Tags: staffing,legal Sources: LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener) - [confirmed] Miles-El distinguished Helling v. McKinney The Sixth Circuit in Miles-El v. State of Michigan distinguished Helling v. McKinney, 509 U.S. 25 (1993), noting that those cases concern situations afield from the one before it. Date: 2026-10-09 Tags: legal Sources: Kushawn Miles-El v. State of Michigan, Court of Appeals for the Sixth Circuit, 2026-10-09 (court record via CourtListener) - [confirmed] Cason v. Seckinger: class of all male and female inmates at Middle Georgia Correctional Complex The Cason v. Seckinger lawsuit was filed on behalf of a class of all male and female inmates presently or in the future housed by GDC at the Middle Georgia Correctional Complex, seeking injunctive relief for numerous alleged constitutional violations. Date: 1984-01-01 Tags: legal,facilities,conditions Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Conditions claims use deliberate-indifference standard, not malicious intent The Supreme Court held that an Eighth Amendment conditions-of-confinement claim requires a culpable state of mind (the deliberate-indifference standard used for medical-care claims), not malicious and sadistic intent; it vacated the Sixth Circuit's judgment and remanded because that court applied the wrong (Whitley) standard, and it rejected the contention that no condition can be found to fail the serious-deprivation test in isolation. Date: 1990-01-01 Tags: legal,conditions,medical Sources: October Term, 1990 - [confirmed] PLRA prerequisite for prisoner release orders No court shall enter a prisoner release order in a civil action with respect to prison conditions unless a court has previously entered an order for less intrusive relief that has failed to remedy the deprivation of the Federal right sought to be remedied through the prisoner release order. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Goodman v. Kimbrough: policy deviation does not relieve plaintiff of showing subjective awareness In Goodman v. Kimbrough, the Eleventh Circuit held that deviation from policy or unreasonable actions by officers does not relieve a plaintiff of the burden of showing the officers were subjectively aware of the risk; a plaintiff cannot say 'Well, they should have known.' Date: 2013-06-21 Tags: legal,conditions,policy Sources: Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener) - [confirmed] Hourly rate cap for attorney's fees under § 1997e 42 U.S.C. § 1997e provides that no award of attorney's fees in such an action shall be based on an hourly rate greater than 150 percent of the hourly rate established under section 3006A of title 18 for payment of court-appointed counsel. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] 42 U.S.C. § 1997c: Attorney General must personally sign certification 42 U.S.C. § 1997c requires the Attorney General to personally sign any certification made pursuant to this section. Tags: legal,policy Sources: law.cornell.edu: 1997c - [confirmed] PLRA prospective relief must be narrowly drawn and least intrusive Section 3626 of title 18 provides that a court shall not grant or approve prospective relief in a prison-conditions case unless the court finds that such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right, and that the court shall give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the relief. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [reported] Guthrie v. Evans: unnamed class member could not appeal On April 24, 1987, the Eleventh Circuit, in an opinion by Chief Judge Paul H. Roney, held that an unnamed class member could not appeal the final judgment of the district court in Guthrie v. Evans. Date: 1987-04-24 Tags: legal Sources: Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page - [confirmed] Prisoner release orders require a three-judge court 18 U.S.C. § 3626 provides that in any civil action in Federal court with respect to prison conditions, a prisoner release order shall be entered only by a three-judge court in accordance with 28 U.S.C. § 2284, and only if the requirements of subparagraph (E) have been met. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] Miller v. French upholds mandatory PLRA automatic stay In Miller v. French, the Supreme Court held that Congress clearly intended the PLRA's automatic stay to be mandatory, so courts cannot use their equitable powers to enjoin the stay, and that the provision does not violate separation of powers principles. Date: 2000-06-19 Tags: legal,policy Sources: Miller v. French, Supreme Court of the United States, 2000-06-19 (court record via CourtListener) - [confirmed] Hutto v. Finney abrogation noted in Sixth Circuit The Sixth Circuit (Pearson v. MDOC, 2026) cited Hutto v. Finney, 437 U.S. 678, 683 (1978), noting it was abrogated on other grounds, in the context of conditions-of-confinement precedent. Tags: legal,conditions Sources: Machelle Pearson v. MDOC, Court of Appeals for the Sixth Circuit, 2026-03-26 (court record via CourtListener) - [confirmed] Lewis v. Casey reversed systemwide access-to-courts injunction Reversing the Ninth Circuit's affirmance of a systemwide access-to-courts injunction against the Arizona prison system, the Supreme Court held that inmates must show actual injury, that the remedy must be limited to the inadequacy that produced the injury shown, and that the two instances of actual injury found (both illiterate prisoners) did not prove violations pervading the state's prisons, so systemwide relief was improper. Tags: legal Sources: law.cornell.edu: 343 - [confirmed] Chandler v. Crosby: vicarious exhaustion for Rule 23(b)(2) prisoner class A class of prisoner-plaintiffs certified under Rule 23(b)(2) satisfies the PLRA's administrative exhaustion requirement through vicarious exhaustion, meaning exhaustion is satisfied when one or more class members has exhausted administrative remedies with respect to each claim raised by the class. Date: 2004-08-06 Tags: legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Bread-and-water diet and environmental hazards enjoined January 7, 1980 On December 10, 1979, plaintiffs in Guthrie v. Evans moved for immediate relief from serious environmental hazards and to end bread-and-water diet punishment; on January 7, 1980, the court entered an order enjoining those conditions and practices at Georgia State Prison. Date: 1980-01-07 Tags: legal,conditions,solitary Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Dockery v. Cain: EMCF class and solitary-confinement subclass certified In Dockery v. Cain, the Fifth Circuit noted that the district court had certified a general class of East Mississippi Correctional Facility inmates and three subclasses, including one for all prisoners in solitary confinement, in a class action alleging Eighth Amendment violations regarding mental health care, medical care, solitary confinement, excessive force, protection from violence, sanitation, and nutrition and food safety. Date: 2021-08-05 Tags: solitary,mental_health,medical,violence,conditions,legal Sources: Dockery v. Cain, U.S. Court of Appeals, 5th Circuit, 2021-08-05 (court record via CourtListener) - [confirmed] Cason v. Seckinger: consent decrees entered May 10, 1990 to March 29, 1996 Cason v. Seckinger arose from a lawsuit on behalf of a class of all male and female inmates housed by GDC at the Middle Georgia Correctional Complex, resolved by a series of consent decrees entered between May 10, 1990 and March 29, 1996; on November 12, 1998 defendants moved to terminate all remaining decrees under the PLRA. Tags: legal,policy Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Purcell: excessive risk of inmate-on-inmate violence creates substantial risk of serious harm In Purcell v. Toombs County, the Eleventh Circuit held that an excessive risk of inmate-on-inmate violence at a jail creates a substantial risk of serious harm, but that occasional, isolated attacks by one prisoner on another may not constitute cruel and unusual punishment, while confinement in a prison where violence and terror reign is actionable; a prisoner has a right to be reasonably protected from a constant threat of violence. Date: 2005-02-24 Tags: legal,violence Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Remedy for unsafe conditions need not await a tragic event The Court in Helling v. McKinney stated that the Courts of Appeals have plainly recognized that a remedy for unsafe conditions need not await a tragic event. Date: 1992-01-01 Tags: legal,conditions,death Sources: October Term, 1992 - [confirmed] PLRA reasonable-time requirement for prisoner release orders A prisoner release order requires that the defendant has had a reasonable amount of time to comply with the previous court orders, in addition to a prior order for less intrusive relief that failed to remedy the deprivation of the Federal right sought to be remedied through the prisoner release order. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Goodman v. Kimbrough: summary judgment affirmed for jail officers and sheriff The Eleventh Circuit affirmed summary judgment for two county-jail officers and the sheriff in a pretrial detainee's Fourteenth Amendment deliberate-indifference suit. The officers' failure to do required cell checks and head counts, and their deactivation of a call button, showed negligence or perhaps gross negligence but no evidence of subjective awareness of a risk to the detainee. Policy violations also did not show a custom supporting official-capacity liability. Date: 2013-06-21 Tags: legal,conditions,staffing Sources: Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener) - [confirmed] Physical injury requirement for mental or emotional injury claims 42 U.S.C. § 1997e provides that no Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in custody without a prior showing of physical injury or the commission of a sexual act as defined in section 2246 of title 18. Tags: legal,mental_health Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] Definition of prisoner under § 1997e 42 U.S.C. § 1997e defines 'prisoner' to mean any person incarcerated or detained in any facility who is accused of, convicted of, sentenced for, or adjudicated delinquent for, violations of criminal law or the terms and conditions of parole, probation, pretrial release, or diversionary program. Tags: legal,policy Sources: Prison Litigation Reform Act, 42 U.S.C. § 1997e - [confirmed] 42 U.S.C. § 1997c: Attorney General must personally sign intervention motion Section 1997c of title 42 provides that the Attorney General shall personally sign any motion to intervene made pursuant to that section. Tags: legal,policy Sources: law.cornell.edu: 1997c - [confirmed] Prisoner release order requires three-judge court Section 3626 of title 18 provides that in any civil action in Federal court with respect to prison conditions, a prisoner release order shall be entered only by a three-judge court in accordance with section 2284 of title 28, if the requirements of the clear-and-convincing-evidence subparagraph have been met. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] PLRA: prisoner release order requires three-judge court 18 U.S.C. § 3626(a)(3)(B) provides that a prisoner release order can be entered only by a three-judge court. Date: 2020-04-04 Tags: legal,policy Sources: Plata v. Newsom, 2020-04-04 (court record via CourtListener) - [confirmed] Prospective relief survives termination only with written findings of ongoing violation Under 18 U.S.C. § 3626, prospective relief shall not terminate if the court makes written findings based on the record that it remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary, and is narrowly drawn and the least intrusive means. The document notes this is the text quoted in Miller v. French, which paraphrases 'shall not terminate' as 'may not terminate'. Tags: legal,policy Sources: law.cornell.edu: 3626 - [confirmed] PLRA restricts prospective relief to findings-supported, narrowly tailored remedies Miller v. French states that the PLRA has restricted courts' authority to issue and enforce prospective relief concerning prison conditions, requiring that such relief be supported by findings and precisely tailored to what is needed to remedy the violation of a federal right. Date: 2000-06-19 Tags: legal,policy Sources: Miller v. French, Supreme Court of the United States, 2000-06-19 (court record via CourtListener) - [confirmed] Hale v. Tallapoosa County and Anderson cited on conditions standards The Seventh Circuit (Balle v. Kennedy, 2023) cited Anderson, 835 F.3d at 683 and Hale v. Tallapoosa County, 50 F.3d at 1583-84, on conditions-of-confinement standards. Date: 2023-01-01 Tags: legal,conditions Sources: Willie Balle v. David Kennedy, Court of Appeals for the Seventh Circuit, 2023-07-14 (court record via CourtListener) - [confirmed] Hutto v. Finney: 30-day limit on punitive isolation upheld In Hutto v. Finney, the Supreme Court held that the District Court did not err in including a 30-day limitation on sentences to punitive isolation as part of its comprehensive remedy to correct constitutional violations in the Arkansas prison system. Tags: legal,solitary Sources: Terrell Don HUTTO et al., Petitioners, v. Robert FINNEY et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Chandler v. Crosby: lead plaintiff's exhaustion satisfied class requirement In Chandler v. Crosby, the lead plaintiff's exhaustion of his own grievance through all three steps of Florida's grievance process satisfied the PLRA's exhaustion requirement as to the entire certified plaintiff class. Date: 2004-08-06 Tags: legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] New disciplinary system implemented April 20, 1981 It was not until April 20, 1981, that the offending disciplinary practices were terminated and a new, agreed-upon constitutional disciplinary system was implemented at Georgia State Prison in Guthrie v. Evans. Date: 1981-04-20 Tags: legal,conditions,solitary Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Dockery v. Hall: no constitutional violations found after five-week bench trial After six years of litigation, including a five-week bench trial, the district court in Dockery v. Hall concluded wide-ranging improvements had made EMCF 'not the same [prison] as the one that had existed when this lawsuit was filed,' found no constitutional violations, and denied the plaintiffs' requested injunction; the Fifth Circuit affirmed. Date: 2021-08-05 Tags: legal,conditions,facilities Sources: Dockery v. Cain, U.S. Court of Appeals, 5th Circuit, 2021-08-05 (court record via CourtListener) - [confirmed] Cason v. Seckinger: particularized findings required for each § 3626(b)(3) criterion The Eleventh Circuit held that particularized findings, analysis, and explanations should be made as to the application of each § 3626(b)(3) criterion to each requirement imposed by a consent decree before the decree can be continued. Date: 2000-10-24 Tags: legal Sources: Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener) - [confirmed] Helling v. McKinney: future-harm exposure states an Eighth Amendment claim The Supreme Court held that by alleging that petitioners have, with deliberate indifference, exposed him to environmental tobacco smoke levels that pose an unreasonable risk to his future health, McKinney has stated an Eighth Amendment claim on which relief could be granted, and that an injunction cannot be denied to inmates who plainly prove an unsafe, life-threatening condition on the ground that nothing yet has happened to them. Date: 1992-01-01 Tags: legal,conditions,medical Sources: October Term, 1992 - [confirmed] Prisoner release orders require a three-judge court A prisoner release order in Federal court with respect to prison conditions shall be entered only by a three-judge court in accordance with section 2284 of title 28, if the requirements of subparagraph (E) have been met. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Holmes v. Continental Can: Rule 23(b)(2) class must be homogeneous without conflicting interests In Holmes v. Continental Can Co., the Eleventh Circuit explained that Rule 23(b)(2)'s 'very nature' requires that the class 'is homogeneous without any conflicting interests between the members of the class,' quoting Wetzel v. Liberty Mutual Insurance Co., and that subsection (b)(2) 'clearly envisions a class defined by the homogeneity and cohesion of its members' grievances, rights and interests.' Date: 1983-06-09 Tags: legal Sources: 31 Fair empl.prac.cas. 1707, 32 Empl. Prac. Dec. P 33,668 Gloria Holmes v. Continental Can Company, U.S. Court of Appeals, 11th Circuit, 1983-06-09 (court record via CourtListener) - [confirmed] Sua sponte dismissal provision in § 1997e (govinfo version) The court shall on its own motion or on the motion of a party dismiss any action brought with respect to prison conditions under section 1983 of title 42, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility if the court is satisfied that the action is frivolous, malicious, fails to state a claim upon which relief can be granted, or seeks monetary relief from a defendant who is immune from such relief. Tags: legal,policy Sources: § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212 - [confirmed] Kingsley v. Hendrickson: Eighth Amendment cases not relevant to pretrial detainee standard The Supreme Court held that Whitley v. Albers and Hudson v. McMillian lack relevance to the objective-reasonableness standard for a pretrial detainee's excessive force claim because they involved claims brought by convicted prisoners under the Eighth Amendment's Cruel and Unusual Punishment Clause, not claims brought by pretrial detainees under the Fourteenth Amendment's Due Process Clause. Date: 2015-06-22 Tags: legal,violence Sources: Kingsley v. Hendrickson, Supreme Court of the United States, 2015-06-22 (court record via CourtListener) - [confirmed] Prisoner release order requires clear and convincing evidence crowding is primary cause Section 3626 of title 18 provides that the three-judge court shall enter a prisoner release order only if the court finds by clear and convincing evidence that crowding is the primary cause of the violation of a Federal right and that no other relief will remedy the violation of the Federal right. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Three-judge court crowding standard: clear and convincing evidence 18 U.S.C. § 3626 allows a three-judge court to enter a prisoner release order only if it finds by clear and convincing evidence that crowding is the primary cause of the violation of a Federal right and that no other relief will remedy the violation. Tags: legal,policy Sources: law.cornell.edu: 3626 - [reported] Valentine v. Collier: failing to do the impossible is not deliberate indifference The Fifth Circuit in Valentine v. Collier quoted the Eleventh Circuit's Swain v. Junior for the proposition that failing to do the impossible does not evince indifference, let alone deliberate indifference, in rejecting the district court's fault-finding that TDCJ never considered using early release to increase social distancing. Date: 2020-10-13 Tags: legal,conditions,reentry Sources: Laddy Valentine v. Bryan Collier, U.S. Court of Appeals, 5th Circuit, 2020-10-13 (court record via CourtListener) - [confirmed] Hutto v. Finney: court authority to address each element of violation In Hutto v. Finney, the Court stated that in fashioning a remedy, the District Court had ample authority to go beyond earlier orders and to address each element contributing to the constitutional violation. Tags: legal Sources: Terrell Don HUTTO et al., Petitioners, v. Robert FINNEY et al. | Supreme Court | US Law | LII / Legal Information Institute - [confirmed] Chandler v. Crosby: objective component requires unreasonable risk of serious damage In Chandler v. Crosby, the Eleventh Circuit held that under the objective component of an Eighth Amendment conditions claim, a prisoner must show that the condition he complains of is sufficiently serious, and at minimum that it poses an unreasonable risk of serious damage to his future health or safety. Date: 2004-08-06 Tags: legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] November 1981 stipulation resolving contempt motion On November 13, 1981, the parties in Guthrie v. Evans submitted a Stipulation resolving plaintiffs' motion for contempt or enforcement of the August 4, 1978 order; the court entered a preliminary order approving the agreement and heard objections on December 15, 1981 before confirming the Stipulation as an order of the court. Date: 1981-11-13 Tags: legal,conditions Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] Dockery v. Fischer: proposed EMCF class and three subclasses In Dockery v. Fischer, plaintiffs moved to proceed as a class of all persons currently or in the future confined at the East Mississippi Correctional Facility (the 'EMCF Class'), along with three subclasses: the Isolation Subclass, the Mental Health Subclass, and the Units 5 and 6 Subclass. Date: 2015-09-29 Tags: solitary,mental_health,legal Sources: Dockery v. Fischer, 2015-09-29 (court record via CourtListener) - [confirmed] Gilmore v. GDC: en banc court discussed Taylor v. Riojas obvious-clarity standard In Gilmore v. Georgia Department of Corrections, the en banc Eleventh Circuit discussed the Supreme Court's decision in Taylor v. Riojas, which reversed a grant of qualified immunity to Texas correctional officers who housed an inmate in a cell covered nearly floor to ceiling in massive amounts of feces and then in a frigidly cold cell with only a clogged drain, finding the violation was one of obvious clarity even without a prior case with identical facts. Date: 2025-07-11 Tags: legal,conditions Sources: Clarissa Gilmore v. Georgia Department of Corrections, U.S. Court of Appeals, 11th Circuit, 2025-07-11 (court record via CourtListener) - [confirmed] Marsh v. Butler County list of conditions supporting substantial-risk finding Purcell v. Toombs County summarized Marsh v. Butler County's list of jail conditions sufficient at the pleading stage to establish a substantial risk of inmate-on-inmate violence, including no segregation of violent from nonviolent inmates, overcrowding beyond cell capacity, the jail being routinely understaffed, no head counts, nonfunctional cell door locks allowing inmates to roam freely, and readily available homemade weapons. Date: 2005-02-24 Tags: legal,violence,conditions,staffing Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Benning v. Oliver enforcement concerned SOP 204.10 email-contact restriction The Benning v. Oliver motion to enforce concerned the court's order enjoining GDC 'from enforcing SOP 204.10's email-contact restriction, i.e., limiting an offender's email contacts to those 12 persons who have been cleared to be on that offender's in-person visitation list.' Date: 2026-02-10 Tags: legal,policy Sources: Court record, M.D. Ga., 2026-02-10 (court record via CourtListener) - [confirmed] Helling v. McKinney: future effects of ETS properly decided The Court held it was not improper for the Court of Appeals to decide the question whether McKinney's claim could be based on possible future effects of environmental tobacco smoke exposure, i.e. that ETS exposure could endanger one's future, not just current, health. Date: 1992-01-01 Tags: legal,conditions,medical Sources: October Term, 1992 - [confirmed] Clear and convincing evidence standard for prisoner release orders A three-judge court shall enter a prisoner release order only if the court finds by clear and convincing evidence that crowding is the primary cause of the violation of a Federal right and that no other relief will remedy the violation of the Federal right. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Physical injury requirement (govinfo version) No Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in custody without a prior showing of physical injury or the commission of a sexual act as defined in section 2246 of title 18. Tags: legal,mental_health Sources: § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212 - [confirmed] Hudson v. McMillian: excessive force and conditions claims are different in kind The Court stated that the dissent's argument that excessive force claims and conditions-of-confinement claims are no different in kind is unfounded, because to deny the difference between punching a prisoner in the face and serving him unappetizing food is to ignore the obvious. Tags: legal,violence,conditions Sources: Cases Adjudged (tile.loc.gov) - [confirmed] State and local officials have standing to oppose prisoner release orders Section 3626 of title 18 provides that any State or local official including a legislator or unit of government whose jurisdiction or function includes the appropriation of funds for the construction, operation, or maintenance of prison facilities, or the prosecution or custody of persons who may be released from, or not admitted to, a prison as a result of a prisoner release order shall have standing to oppose the imposition or continuation in effect of such relief and to seek termination of such relief, and shall have the right to intervene in any proceeding relating to such relief. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Valentine v. Collier: PLRA narrow-tailoring for preliminary relief The Fifth Circuit held the PLRA mandates that preliminary injunctive relief be narrowly drawn, extend no further than necessary to correct the harm requiring preliminary relief, and be the least intrusive means necessary to correct that harm (18 U.S.C. § 3626(a)(2)). Date: 2020-04-22 Tags: legal,policy Sources: Laddy Valentine v. Bryan Collier, U.S. Court of Appeals, 5th Circuit, 2020-04-22 (court record via CourtListener) - [confirmed] Brown v. Plata: 137.5% population cap upheld In Brown v. Plata, the three-judge court's conclusion that the prison population should be capped at 137.5% of design capacity was not clearly erroneous, the evidence supporting a limit between the 130% limit supported by expert testimony and the Federal Bureau of Prisons and the 145% limit recommended by the State Corrections Independent Review Panel. Tags: legal,conditions,facilities Sources: Brown v. Plata, 09 1233.ZS - [reported] Money v. Pritzker: PLRA barred the TRO sought on the Section 1983 claim In Money v. Pritzker, the court held that the PLRA prevented it from granting the temporary restraining order sought on the Section 1983 claim. Tags: legal,policy Sources: Case: 1:20-cv-02093 Document #: 38 Filed: 04/10/20 Page 1 of 48 PageID #:587 - [confirmed] Marsh v. Butler County abrogated on other grounds by Twombly The Eleventh Circuit's opinion in Mosley v. Zachery states that Marsh v. Butler County, 268 F.3d 1014, 1028 (11th Cir. 2001) (en banc), was abrogated on other grounds by Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). Date: 2020-07-24 Tags: legal Sources: Tommy L. Mosley, Jr. v. Lt. Towanda Zachery, U.S. Court of Appeals, 11th Circuit, 2020-07-24 (court record via CourtListener) - [confirmed] PLRA population reduction order requires three-judge court The Coleman v. Brown three-judge court explained that under the PLRA, a population reduction order can be issued only by a specially convened three-judge court which has made specific findings described in the statute. Date: 2013-01-01 Tags: legal,policy Sources: Coleman v. Brown, District Court, E.D. California, 2013-06-20 (court record via CourtListener) - [confirmed] Wade v. McDade en banc: subjective recklessness standard In Wade v. McDade, the Eleventh Circuit sitting en banc repudiated its prior 'more than mere negligence' and 'more than gross negligence' formulations of the deliberate-indifference standard and held that a plaintiff must prove the defendant acted with subjective recklessness as used in the criminal law, showing the defendant was subjectively aware that his own conduct put the plaintiff at substantial risk of serious harm. Date: 2024-07-10 Tags: legal,medical,conditions Sources: Betty Wade v. Georgia Correctional Health, LLC, U.S. Court of Appeals, 11th Circuit, 2024-07-10 (court record via CourtListener) - [confirmed] Gates v. Collier: totality-of-circumstances rule for Eighth Amendment Gates v. Collier (5th Cir.) is the earliest opinion found for the 'totality' rule that Lane v. Philbin applied. Gates held that factors which may not each rise to constitutional dimensions, overcrowded dormitory barracks, lack of classification, untrained inmates with weapons, lack of supervision by civilian guards, and no procedure for confiscating weapons, together inflict punishment violating the Eighth Amendment, resting on the trial court's findings rather than a statute. Date: 1974-09-20 Tags: conditions,violence,staffing,legal Sources: Nazareth Gates, and United States of America, Plaintiff-Intervenor-Appellee v. John Collier, Superintendent, Mississippi State Penitentiary, Court of Appeals for the Fifth Circuit, 1974-09-20 (court record via CourtListener) - [confirmed] Bryant v. Rich: PLRA exhaustion is a matter in abatement Exhaustion of administrative remedies under the PLRA is treated as a 'matter in abatement' like a jurisdictional defense, so a judge may resolve disputed facts on a motion to dismiss without a jury. Date: 2008-06-20 Tags: legal,policy Sources: Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener) - [confirmed] Purcell: two to three serious fights over nine months insufficient in 100-inmate jail Purcell v. Toombs County holds that in a jail housing over a hundred inmates, evidence of two to three serious inmate fights over a period of nine months and not very many other fights over a four-year span cannot establish that serious inmate-on-inmate violence was frequent and pervasive. Date: 2005-02-24 Tags: legal,violence Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Helling v. McKinney: Eighth Amendment protects against future harm A prisoner states an Eighth Amendment claim by alleging that officials, with deliberate indifference, exposed him to levels of environmental tobacco smoke posing an unreasonable risk of serious damage to his future health; the Eighth Amendment protects against future harm, not only current serious health problems. The Court affirmed and remanded for McKinney to prove both the objective and subjective elements. Date: 1992-01-01 Tags: legal,conditions,medical Sources: October Term, 1992 - [confirmed] Standing to oppose prisoner release orders A State or local official including a legislator or unit of government whose jurisdiction or function includes the appropriation of funds for the construction, operation, or maintenance of prison facilities, or the prosecution or custody of persons who may be released from, or not admitted to, a prison as a result of a prisoner release order shall have standing to oppose the imposition or continuation in effect of such relief and to seek termination of such relief, and shall have the right to intervene in any proceeding relating to such relief. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997a(a): AG authority over egregious or flagrant conditions 42 U.S.C. § 1997a(a) authorizes the Attorney General, whenever there is reasonable cause to believe a State or political subdivision official is subjecting institutionalized persons to 'egregious or flagrant conditions' that deprive them of constitutional or federal rights, to bring an action. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997a - [confirmed] Attorney's fees limits (govinfo version) In any action brought by a prisoner confined to any jail, prison, or other correctional facility, in which attorney's fees are authorized under section 1988 of title 42, such fees shall not be awarded except to the extent that the fee was directly and reasonably incurred in proving an actual violation of the plaintiff's rights protected by a statute pursuant to which a fee may be awarded under section 1988, and the amount of the fee is proportionately related to the court ordered relief for the violation, or the fee was directly and reasonably incurred in enforcing the relief ordered for the violation. Tags: legal,policy Sources: § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212 - [confirmed] Prospective relief terminable upon motion after two years Section 3626 of title 18 provides that in any civil action with respect to prison conditions in which prospective relief is ordered, such relief shall be terminable upon the motion of any party or intervener two years after the date the court granted or approved the prospective relief, one year after the date the court has entered an order denying termination of prospective relief, or in the case of an order issued on or before the date of enactment of the Prison Litigation Reform Act, two years after such date of enactment. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Valentine v. Collier: PLRA requires weight to public safety and comity The Fifth Circuit noted the PLRA requires courts to give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by preliminary relief and to respect principles of comity in tailoring relief. Date: 2020-04-22 Tags: legal,policy Sources: Laddy Valentine v. Bryan Collier, U.S. Court of Appeals, 5th Circuit, 2020-04-22 (court record via CourtListener) - [confirmed] Miller v. French: PLRA automatic stay is mandatory The Supreme Court held in Miller v. French that Congress, through the PLRA, clearly intended to make operation of the automatic stay mandatory, precluding courts from exercising their equitable powers to enjoin the stay, and that this provision does not violate separation of powers principles. Tags: legal Sources: Miller v. French - [reported] Money v. Pritzker quotes Coleman/Plata on deference to voluntary prison measures The court in Money v. Pritzker quoted the Coleman/Plata three-judge court's emphasis that defendants have broad authority to voluntarily take steps that may prevent the life-threatening spread of COVID-19 within their prisons, and recognized the deference due to prison authorities to determine which additional measures must be taken. Tags: legal,conditions,policy Sources: Case: 1:20-cv-02093 Document #: 38 Filed: 04/10/20 Page 1 of 48 PageID #:587 - [confirmed] Braggs v. Dunn: ADOC mental-health care 'horrendously inadequate' and violated Eighth Amendment In Braggs v. Dunn, the court found that ADOC's mental-health care for prisoners in its custody was, simply put, horrendously inadequate and violated the Eighth Amendment. Date: 2019-05-04 Tags: legal,mental_health,medical Sources: Braggs v. Dunn, 2019-05-04 (court record via CourtListener) - [confirmed] Braggs v. Dunn: deliberate indifference found despite repeated notice of deficiencies In Braggs v. Dunn, the court held that proving an Eighth Amendment violation requires showing both that officials subjected mentally ill prisoners to a substantial risk of serious harm and that defendants acted with deliberate indifference to that risk, and found that despite being repeatedly informed that significant deficiencies existed, ADOC disregarded and failed to respond reasonably to the actual harm and substantial risk of serious harm facing mentally ill prisoners in its custody. Tags: legal,mental_health Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Brown v. Plata: overcrowding as primary cause The three-judge court found that overcrowding was the 'primary cause' of the federal rights violation in the sense of being the foremost cause of the violation, which the Supreme Court held consistent with the text of the PLRA. Tags: legal,conditions Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Wade v. McDade: reasonable response defeats liability even with actual knowledge The en banc Eleventh Circuit in Wade v. McDade held that even if the defendant actually knew of a substantial risk to inmate health or safety, he cannot be found liable under the Cruel and Unusual Punishments Clause if he responded reasonably to that risk. Date: 2024-07-10 Tags: legal,medical,conditions Sources: Betty Wade v. Georgia Correctional Health, LLC, U.S. Court of Appeals, 11th Circuit, 2024-07-10 (court record via CourtListener) - [confirmed] Postawko v. Missouri DOC: HCV treatment class certified In Postawko v. Missouri Department of Corrections, the Eighth Circuit affirmed certification of a class defined as 'All those individuals in the custody of MDOC, now or in the future, who have been, or will be, diagnosed with chronic HCV, as that term is defined medically, but who are not provided treatment with direct acting antiviral drugs.' Date: 2018-12-06 Tags: medical,legal Sources: Michael Postawko v. Missouri Dept of Corrections, U.S. Court of Appeals, 8th Circuit, 2018-12-06 (court record via CourtListener) - [confirmed] Bryant v. Rich: judge may act as factfinder on PLRA exhaustion defense In Bryant v. Rich, a case brought by Georgia prisoners, the Eleventh Circuit held that a district judge may act as factfinder on a PLRA exhaustion defense, considering facts outside the pleadings and resolving factual disputes so long as they do not decide the merits and the parties have sufficient opportunity to develop a record. Date: 2008-06-20 Tags: legal,policy Sources: Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener) - [confirmed] Purcell acknowledges possible Eighth Amendment claim absent history of violence Purcell v. Toombs County acknowledges that it might be possible, in certain circumstances, to base an Eighth Amendment violation on inmate-on-inmate violence in the absence of a history of such violence, citing Marsh. Date: 2005-02-24 Tags: legal,violence Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Termination timing for prospective relief Prospective relief in a civil action with respect to prison conditions shall be terminable upon the motion of any party or intervener 2 years after the date the court granted or approved the prospective relief, or 1 year after the date the court has entered an order denying termination of prospective relief, or in the case of an order issued on or before the date of enactment of the Prison Litigation Reform Act, 2 years after such date of enactment. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997b(a): 49-day pre-suit notice requirement 42 U.S.C. § 1997b(a) and (a)(1) require that at the time of commencing a § 1997a action, the Attorney General certify to the court that at least 49 calendar days previously the Attorney General notified in writing the Governor or chief executive officer, attorney general or chief legal officer, and the director of the institution. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997b - [confirmed] Judgment offset and hourly rate cap (govinfo version) Whenever a monetary judgment is awarded in an action for attorney's fees under section 1997e(d)(1), a portion of the judgment not to exceed 25 percent shall be applied to satisfy the amount of attorney's fees awarded against the defendant, and if the award of attorney's fees is not greater than 150 percent of the judgment, the excess shall be paid by the defendant, and no award of attorney's fees shall be based on an hourly rate greater than 150 percent of the hourly rate established under section 3006A of title 18 for payment of court-appointed counsel. Tags: legal,policy Sources: § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212 - [confirmed] Jones v. Bock: PLRA exhaustion is an affirmative defense Failure to exhaust administrative remedies under the PLRA is an affirmative defense that defendants must plead and prove, and inmates are not required to specially plead or demonstrate exhaustion in their complaints. Date: 2007-01-22 Tags: legal,policy Sources: Jones v. Bock, Supreme Court of the United States, 2007-01-22 (court record via CourtListener) - [confirmed] Prospective relief shall not terminate if ongoing violation remains Section 3626 of title 18 provides that prospective relief shall not terminate if the court makes written findings based on the record that prospective relief remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary to correct the violation of the Federal right, and that the prospective relief is narrowly drawn and the least intrusive means to correct the violation. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] CRIPA does not expand or restrict other parties' enforcement authority 42 U.S.C. § 1997j provides that the CRIPA subchapter shall in no way expand or restrict the authority of parties other than the United States to enforce legal rights they may have under existing law regarding institutionalized persons. Tags: legal,policy Sources: law.cornell.edu: 1997j - [confirmed] Miller v. French: automatic stay alters underlying law, not a rule of decision The Court held that § 3626(e)(2)'s automatic stay does not violate separation of powers because, by establishing new standards for the enforcement of prospective relief in § 3626(b), Congress altered the relevant underlying law, and the automatic stay helps implement that change rather than dictating a rule of decision in a pending case. Tags: legal Sources: Miller v. French - [confirmed] PLRA: only a three-judge court may enter a prisoner release order The statute provides that only a three-judge court can enter a prisoner release order, 18 U.S.C. § 3626(a)(3)(B), so a single district judge standing alone lacks authority to issue any order with the purpose or effect of reducing or limiting the prison population. Tags: legal,policy,reentry Sources: Case: 1:20-cv-02093 Document #: 38 Filed: 04/10/20 Page 1 of 48 PageID #:587 - [confirmed] Braggs v. Dunn: inadequate crisis and suicide-prevention care created substantial risk of serious harm In Braggs v. Dunn, the court found that ADOC's inadequate crisis care and long-term suicide-prevention measures have created a substantial risk of serious harm, including self-harm, suicide, and continued pain and suffering. Date: 2019-05-04 Tags: legal,mental_health,death Sources: Braggs v. Dunn, 2019-05-04 (court record via CourtListener) - [confirmed] Braggs v. Dunn: Commissioner and Associate Commissioner held in violation of Eighth Amendment After a bench trial on the Eighth Amendment phase, the district court held that ADOC's Commissioner and Associate Commissioner of Health Services, in their official capacities, were violating the Eighth Amendment rights of the class of prisoners with serious mental-health needs because ADOC's mental-health care was inadequate and the officials were deliberately indifferent to the risk. Tags: legal,mental_health Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Brown v. Plata: substantial weight to public safety The Court held that the PLRA's requirement that a court give 'substantial weight' to public safety does not require the court to certify that its order has no possible adverse impact on the public, because that would replace the statutory word 'substantial' with 'conclusive.' Tags: legal,policy Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Braggs v. Dunn cited on untreated serious medical risk Office of the Public Guardian v. Elliot Hospital followed Braggs v. Dunn, 257 F. Supp. 3d (M.D. Ala.), regarding substantial risk of harm if a condition is left untreated. Date: 2022-09-15 Tags: medical,mental_health,legal Sources: Office of the Public Guardian v. P Elliot Hospital, et al., District Court, D. New Hampshire, 2022-09-15 (court record via CourtListener) - [confirmed] Bryant v. Rich: transferred prisoner who feared reprisal failed to exhaust via out-of-time grievance In Bryant v. Rich, the Eleventh Circuit held that a Georgia prisoner who feared violent reprisal at the prison where the abuse occurred, but was later transferred to another prison where the threat of violence was removed, failed to exhaust because he could have filed an out-of-time grievance there and shown good cause. Date: 2008-06-20 Tags: legal,transfers,violence Sources: Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener) - [confirmed] Hamm v. DeKalb County: overcrowding and inadequate care not unconstitutional In Hamm v. DeKalb County, the Eleventh Circuit affirmed the district court's judgment for jail officials after a nonjury trial, holding that overcrowding exceeding the jail's design capacity, unsanitary food service, and inadequate medical care did not amount to a constitutional deprivation, including when considered in combination. Date: 1985-11-04 Tags: legal,conditions,medical,facilities Sources: George Hamm v. Dekalb County, and Pat Jarvis, Sheriff, U.S. Court of Appeals, 11th Circuit, 1985-11-04 (court record via CourtListener) - [confirmed] Prospective relief continues if ongoing violation found Prospective relief shall not terminate if the court makes written findings based on the record that prospective relief remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary to correct the violation of the Federal right, and that the prospective relief is narrowly drawn and the least intrusive means to correct the violation. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997b: certification must describe alleged conditions and pattern or practice Section 1997b of title 42 provides that at the time of the commencement of an action under section 1997a, the Attorney General shall certify to the court that at least 49 calendar days previously the Attorney General has notified in writing the Governor or chief executive officer and attorney general or chief legal officer of the appropriate State or political subdivision and the director of the institution of the alleged conditions which deprive rights, privileges, or immunities secured or protected by the Constitution or laws of the United States and the alleged pattern or practice of resistance to the full enjoyment of such rights, privileges, or immunities. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997b - [confirmed] Definition of prisoner (govinfo version) As used in section 1997e, the term 'prisoner' means any person incarcerated or detained in any facility who is accused of, convicted of, sentenced for, or adjudicated delinquent for, violations of criminal law or the terms and conditions of parole, probation, pretrial release, or diversionary program. Tags: legal,policy Sources: § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212 - [confirmed] Jones v. Bock: PLRA does not require naming all defendants in grievance The PLRA does not impose a requirement that a prisoner's grievance name every individual defendant later sued; the level of detail required in a grievance is defined by the prison's own grievance procedures, not by the PLRA. Date: 2007-01-22 Tags: legal,policy Sources: Jones v. Bock, Supreme Court of the United States, 2007-01-22 (court record via CourtListener) - [confirmed] Motion to terminate prospective relief operates as a stay Section 3626 of title 18 provides that any motion to modify or terminate prospective relief made under subsection (b) shall operate as a stay during the period beginning on the thirtieth day after such motion is filed, in the case of a motion made under paragraph (1) or (2) of subsection (b), or beginning on the one hundred eightieth day after such motion is filed, in the case of a motion made under any other law, and ending on the date the court enters a final order ruling on the motion. Tags: legal,policy Sources: Page 835 Title 18—CRIMES and Criminal Procedure § 3626 - [confirmed] Marbury: generalized-violence deliberate indifference standard To establish deliberate indifference based on a generalized risk of inmate-on-inmate violence, the plaintiff must show that serious inmate-on-inmate violence was the norm or something close to it; the plaintiff's evidence did not support that such violence was so pervasive as to constitute a substantial risk of serious harm. Date: 2019-08-29 Tags: legal,violence Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [confirmed] DOJ pattern-or-practice authority over institutions under 42 U.S.C. § 1997a 42 U.S.C. § 1997a provides that whenever the Attorney General has reasonable cause to believe a State or political subdivision, its officials, employees, agents, or others acting on its behalf are subjecting persons confined to an institution to egregious or flagrant conditions depriving them of constitutional or federal rights causing grievous harm, pursuant to a pattern or practice of resistance, the Attorney General may institute a civil action in any appropriate U.S. district court for equitable relief to insure the minimum corrective measures necessary. Tags: legal,investigations,conditions Sources: § 1997a TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5244 - [reported] Marbury v. Warden III: Twombly changed assessment of qualitative allegations In Marbury v. Warden III, the Eleventh Circuit stated that Bell Atlantic Corp. v. Twombly, 550 U.S. 554 (2007), makes clear that the plaintiffs' qualitative allegations would be assessed differently than under Marsh v. Butler County. Date: 2026-07-07 Tags: legal Sources: Marbury v. Warden III, U.S. Court of Appeals, 11th Circuit, 2026-07-07 (court record via CourtListener) - [confirmed] Vicarious exhaustion for Rule 23(b)(2) prisoner classes in Dunn v. Dunn In the Braggs/Dunn v. Dunn Alabama prisoner mental-health litigation, the Eleventh Circuit's vicarious-exhaustion rule for Rule 23(b)(2) prisoner classes was applied where the M.D. Ala. district court had, in conjunction with its summary judgment ruling, certified a Rule 23(b)(2) class, citing Chandler v. Crosby, 379 F.3d 1278, 1287 (11th Cir. 2004), that a class of prisoner-plaintiffs certified under Rule 23(b)(2) satisfies the PLRA's administrative exhaustion requirement through 'vicarious exhaustion.' Date: 2016-11-25 Tags: legal,mental_health Sources: Dunn v. Dunn, 2016-11-25 (court record via CourtListener) - [confirmed] Brown v. Plata: systemwide population limit not overbroad The Supreme Court held that a systemwide population-limit order was not overbroad for encompassing the entire California prison system rather than separately assessing the need for a population limit at every institution, because the Coleman court found a systemwide violation and the State stipulated to systemwide relief in Plata. Tags: legal,conditions Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Hinojosa v. Livingston: Chandler temperatures ranged 80-95 degrees The Fifth Circuit in Hinojosa v. Livingston described Chandler v. Crosby as finding no constitutional violation where Florida death-row cell temperatures ranged from 80 to 95 degrees, which the Eleventh Circuit deemed not unconstitutionally excessive, given remedial measures including a ventilation system, cells not in direct sunlight, and prisoners not compelled to wear heavy clothing or perform laborious tasks. Date: 2015-11-18 Tags: conditions,legal Sources: Hinojosa v. Livingston, 807 F.3d 657 (5th Cir. 2015) - [confirmed] Wade v. McDade abrogated Goodman v. Kimbrough The en banc decision in Wade v. McDade / Georgia Correctional Health, LLC abrogated Goodman v. Kimbrough's 'more than gross negligence' element (quoting Townsend). Date: 2024-07-10 Tags: legal Sources: Betty Wade v. Georgia Correctional Health, LLC, U.S. Court of Appeals, 11th Circuit, 2024-07-10 (court record via CourtListener) - [confirmed] Gomes v. DHS distinguished Money v. Pritzker Gomes v. U.S. Department of Homeland Security distinguished Money v. Pritzker, No. 20-CV-2093 (N.D. Ill.), as addressing a narrower issue. Date: 2020-05-14 Tags: legal Sources: Robson Xavier Gomes v. US Department of Homeland Security, Acting Secretary et. al., District Court, D. New Hampshire, 2020-05-14 (court record via CourtListener) - [confirmed] Bryant v. Rich: no discretion to waive PLRA exhaustion Bryant v. Rich states that the Eleventh Circuit has no discretion to waive the PLRA exhaustion requirement. Date: 2008-06-20 Tags: legal,policy Sources: Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener) - [confirmed] Hamm v. DeKalb County: pretrial detainee standard equals Eighth Amendment standard In Hamm v. DeKalb County, the Eleventh Circuit held that for pretrial detainees, the minimum standard the due process clause requires for basic necessities such as food, living space, and medical care is the same as the standard the Eighth Amendment allows for convicted persons. Date: 1985-11-04 Tags: legal,conditions,medical Sources: George Hamm v. Dekalb County, and Pat Jarvis, Sheriff, U.S. Court of Appeals, 11th Circuit, 1985-11-04 (court record via CourtListener) - [confirmed] Consent decrees must comply with § 3626(a) limits In a civil action with respect to prison conditions, the court shall not enter or approve a consent decree unless it complies with the limitations on relief set forth in subsection (a). Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997b: certification must include minimum remedial measures Section 1997b of title 42 requires the Attorney General's pre-suit certification to include the minimum measures which the Attorney General believes may remedy the alleged conditions and the alleged pattern or practice of resistance. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997b - [confirmed] Rule 23(a) class certification prerequisites Under Federal Rule of Civil Procedure 23(a), one or more members of a class may sue or be sued as representative parties on behalf of all members only if the class is so numerous that joinder of all members is impracticable, there are questions of law or fact common to the class, the claims or defenses of the representative parties are typical of the claims or defenses of the class, and the representative parties will fairly and adequately protect the interests of the class. Tags: legal,policy Sources: Rule 23. Class Actions | Federal Rules of Civil Procedure | US Law | LII / Legal Information Institute - [confirmed] Jones v. Bock: no total exhaustion rule under PLRA The PLRA does not impose a 'total exhaustion' rule; when a complaint contains both exhausted and unexhausted claims, a court proceeds with the exhausted claims and dismisses only the unexhausted ones, not the entire action. Date: 2007-01-22 Tags: legal,policy Sources: Jones v. Bock, Supreme Court of the United States, 2007-01-22 (court record via CourtListener) - [confirmed] Marbury: facility features that can support generalized-risk claim Where the Eleventh Circuit has held a generalized risk of violence could support a deliberate-indifference claim, the plaintiff pointed to specific features rendering a facility particularly violent, including pervasive staffing and logistical issues rendering officials unable to address near-constant violence. Date: 2019-08-29 Tags: legal,violence,staffing Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [confirmed] § 1997a equitable relief limited to constitutional deprivations for certain institutions 42 U.S.C. § 1997a provides that such equitable relief shall be available to persons residing in or confined to an institution as defined in § 1997(1)(B)(ii) only insofar as such persons are subjected to conditions which deprive them of rights, privileges, or immunities secured or protected by the Constitution of the United States. Tags: legal,conditions Sources: § 1997a TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5244 - [reported] Marbury v. Warden III: Marsh v. Butler County abrogated on other grounds by Twombly In Marbury v. Warden III, the Eleventh Circuit stated that its en banc decision in Marsh v. Butler County was abrogated on other grounds by Bell Atlantic Corp. v. Twombly. Date: 2026-07-07 Tags: legal Sources: Marbury v. Warden III, U.S. Court of Appeals, 11th Circuit, 2026-07-07 (court record via CourtListener) - [confirmed] Court ordered incarcerated witnesses to testify in person, not by videoconference In United States v. State of Alabama (N.D. Ala.), the court ordered that the testimony of incarcerated witnesses shall be taken in person, in open court, and no incarcerated witness will be permitted to testify by videoconference, telephone, or other contemporaneous transmission from an ADOC facility or any other remote location, except upon a particularized showing of good cause and an order from the court. Date: 2026-01-01 Tags: legal Sources: United States v. State of Alabama, 2026-08-31 (court record via CourtListener) - [confirmed] Bryant v. Rich: consolidated Georgia § 1983 appeals affirmed dismissal without prejudice In two consolidated Georgia prisoner § 1983 appeals, the Eleventh Circuit held that a PLRA exhaustion defense is a matter in abatement, properly raised by a motion to dismiss, on which the district judge may act as factfinder to resolve disputed facts that do not decide the merits. Because neither prisoner exhausted the grievance procedures available to him (including out-of-time grievances for good cause after transfer), it affirmed dismissal without prejudice. Date: 2008-06-20 Tags: legal,policy Sources: Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener) - [confirmed] Purcell objective standard balances dignity concepts against penological goals In Purcell v. Toombs County, the Eleventh Circuit, quoting LaMarca v. Turner, described the objective standard for a substantial risk of serious harm as embodying broad and idealistic concepts of dignity, civilized standards, humanity, and decency, but noted it must be balanced against competing penological goals. Date: 2005-02-24 Tags: legal,conditions Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Hamm v. DeKalb County: failure to apply totality test not prejudicial In Hamm v. DeKalb County, the Eleventh Circuit found the district court's failure to expressly consider overcrowding, food service, and medical care claims together under a totality-of-conditions test was not prejudicial error, citing Ruiz v. Estelle's totality of conditions test. Date: 1985-11-04 Tags: legal,conditions Sources: George Hamm v. Dekalb County, and Pat Jarvis, Sheriff, U.S. Court of Appeals, 11th Circuit, 1985-11-04 (court record via CourtListener) - [confirmed] Private settlement agreements exempt from § 3626(a) limits Nothing in section 3626 shall preclude parties from entering into a private settlement agreement that does not comply with the limitations on relief set forth in subsection (a), if the terms of that agreement are not subject to court enforcement other than the reinstatement of the civil proceeding that the agreement settled, and nothing in the section shall preclude any party claiming that a private settlement agreement has been breached from seeking in State court any remedy available under State law. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997b: Attorney General must personally sign certification Section 1997b of title 42 provides that the Attorney General shall personally sign any certification made pursuant to that section. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997b - [confirmed] Rule 23(b)(2) injunctive relief class actions Under Federal Rule of Civil Procedure 23(b)(2), a class action may be maintained if Rule 23(a) is satisfied and if the party opposing the class has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole. Tags: legal,policy Sources: Rule 23. Class Actions | Federal Rules of Civil Procedure | US Law | LII / Legal Information Institute - [confirmed] Dunn v. Dunn: fluid nature of prison plaintiff class favors certification In Dunn v. Dunn, the M.D. Ala. district court held that 'the fluid nature of a plaintiff class, as in the prison-litigation context, counsels in favor of certification of all present and future members,' quoting its own earlier decision in Henderson v. Thomas. Date: 2016-09-09 Tags: legal Sources: Dunn v. Dunn, 2016-09-09 (court record via CourtListener) - [confirmed] Marbury: threats between inmates are common The Eleventh Circuit stated that threats between inmates are common and do not under all circumstances serve to impute actual knowledge of a substantial risk of harm. Date: 2019-08-29 Tags: legal,violence Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [confirmed] Attorney General must personally sign § 1997a complaints 42 U.S.C. § 1997a provides that the Attorney General shall personally sign any complaint filed pursuant to that section. Tags: legal,investigations Sources: § 1997a TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5244 - [reported] Walker v. Schult cites Chandler v. Crosby as affirming judgment after bench trial The Second Circuit in Walker v. Schult cited Chandler v. Crosby as affirming judgment following a bench trial. Date: 2013-05-23 Tags: legal Sources: Walker v. Schult, Court of Appeals for the Second Circuit, 2013-05-23 (court record via CourtListener) - [confirmed] Hope v. Pelzer: hitching post cruelty gave fair notice of unconstitutionality The Supreme Court held that a reasonable officer would have known that using a hitching post as Hope alleged was unlawful, because the obvious cruelty inherent in the practice should have provided respondents with some notice that their conduct was unconstitutional. Tags: legal,conditions Sources: October Term, 2001 - [reported] Dickinson v. Cochran (quoting Marsh v. Butler County): doing nothing when conditions pose serious harm risk is unreasonable In Marsh v. Butler County, as quoted by the Eleventh Circuit in Dickinson v. Cochran, it is an unreasonable response for an official to do nothing when confronted with prison conditions that pose a risk of serious physical harm to inmates. Date: 2020-10-28 Tags: legal,conditions Sources: Joshua Dickinson v. Sam Cochran, U.S. Court of Appeals, 11th Circuit, 2020-10-28 (court record via CourtListener) - [confirmed] Brown v. Plata: PLRA authorizes population limit remedy The Supreme Court held that the PLRA authorizes the relief and that the court-mandated population limit is necessary to remedy the violation of prisoners' constitutional rights, affirming the three-judge court's order. Tags: legal,policy Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Dewalt v. Hooks followed Braggs v. Dunn The Supreme Court of North Carolina in Dewalt v. Hooks followed Braggs v. Dunn, 257 F. Supp. 3d (M.D. Ala.), regarding class-wide conditions to which all class members were subjected. Date: 2022-11-04 Tags: legal Sources: Dewalt v. Hooks, Supreme Court of North Carolina, 2022-11-04 (court record via CourtListener) - [confirmed] Dimanche v. Brown: no need to grieve a breakdown in the grievance process The PLRA does not require a Georgia inmate to file a grievance about a breakdown in the grievance process itself, such as a warden destroying a properly filed grievance. Date: 2015-04-17 Tags: legal,policy Sources: Moliere Dimanche, Jr. v. Jerry Brown, U.S. Court of Appeals, 11th Circuit, 2015-04-17 (court record via CourtListener) - [confirmed] Immediate termination of prospective relief absent required findings In any civil action with respect to prison conditions, a defendant or intervener shall be entitled to the immediate termination of any prospective relief if the relief was approved or granted in the absence of a finding by the court that the relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] 42 U.S.C. § 1997b: certification of reasonable time to correct conditions Section 1997b of title 42 requires the Attorney General to certify that the Attorney General is satisfied that the appropriate officials have had a reasonable time to take appropriate action to correct such conditions and pattern or practice, taking into consideration the time required to remodel or make necessary changes in physical facilities or relocate residents, reasonable legal or procedural requirements, and the urgency of the need to correct such conditions. Tags: legal,policy,investigations Sources: law.cornell.edu: 1997b - [confirmed] Length of confinement relevant to constitutional standards The Supreme Court stated that it is equally plain that the length of confinement cannot be ignored in deciding whether the confinement meets constitutional standards. Tags: legal,conditions,solitary Sources: October Term, 1977 - [confirmed] Marbury: fifteen witnessed stabbings insufficient The Eleventh Circuit held that a plaintiff's statement that he personally witnessed fifteen inmate-on-inmate stabbings, possibly over six years (a rate of 2.5 per year), did not support the conclusion that serious violence was so pervasive as to constitute a substantial risk of serious harm. Date: 2019-08-29 Tags: legal,violence Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [reported] M.D. v. Perry applies Wal-Mart commonality to proposed class In M.D. v. Perry, the Fifth Circuit held that under Wal-Mart's standard for Rule 23 commonality, a proposed class must prove that the claims of every class member depend upon a common contention that is capable of classwide resolution, meaning that determination of the contention's truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke. Date: 2012-03-23 Tags: legal Sources: M.D. Ex Rel. Stukenberg v. Perry, U.S. Court of Appeals, 5th Circuit, 2012-03-23 (court record via CourtListener) - [confirmed] Wilson v. Seiter: conditions claims require culpable state of mind; deliberate indifference applies generally Wilson v. Seiter held that a prisoner claiming that the conditions of his confinement violate the Eighth Amendment must show a culpable state of mind on the part of prison officials, and that the deliberate indifference standard applied in Estelle v. Gamble to medical care claims applies generally to prisoner challenges to conditions of confinement. Date: 1991-01-01 Tags: legal,conditions,medical Sources: Wilson v. Seiter | 501 U.S. 294 (1991) | Justia U.S. Supreme Court Center - [confirmed] United States v. State of Alabama set for bench trial November 30, 2026 In United States v. State of Alabama (N.D. Ala.), the court's Order Setting Trial, Pretrial Conference and Pretrial Deadlines set the case for bench trial on 11/30/2026 at 9:00 a.m., with a pretrial conference on 10/30/2026 at 10:00 a.m. and a hearing on all motions in limine including any outstanding Daubert motions on 11/20/2026 at 1:00 p.m. Date: 2026-01-01 Tags: legal Sources: United States v. State of Alabama, 2026-08-31 (court record via CourtListener) - [confirmed] Brown v. Plata: population limit not clearly erroneous The three-judge court's weighing of the evidence in setting the population limit, found by the evidence to lie between the limit supported by expert testimony and the higher maximum limit found by the State's own Corrections Independent Review Panel, was not clearly erroneous. Tags: legal,conditions Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Yates v. Collier: Pack Unit heat class and subclasses certified In Yates v. Collier, the Fifth Circuit affirmed certification of a general class and two subclasses of inmates at the Wallace Pack Unit (Texas) bringing Eighth Amendment and disability claims over excessive heat, defining the General Class as all inmates currently or in the future incarcerated at the Pack Unit subjected to TDCJ's policy and practice of failing to regulate high indoor heat index temperatures in the housing areas. Date: 2017-08-18 Tags: conditions,facilities,legal Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [confirmed] Whatley v. Warden: transfers not grievable under Georgia SOP In Whatley's case, a prison official explained that his 'imminent danger' grievance about being beaten and transferred without treatment addressed prisoner transfers, which according to Georgia's grievance SOP are not grievable issues. Date: 2015-09-23 Tags: legal,transfers,violence,policy Sources: Shawn Wayne Whatley v. Warden, Ware State Prison, U.S. Court of Appeals, 11th Circuit, 2015-09-23 (court record via CourtListener) - [confirmed] Purcell reversed: conditions did not pose substantial risk; sheriff entitled to Eleventh Amendment immunity On interlocutory appeal from denial of qualified immunity and Eleventh Amendment immunity, the Eleventh Circuit reversed in Purcell v. Toombs County: as a matter of law the Toombs County Jail conditions did not pose a substantial risk of serious harm, so no Eighth Amendment violation was shown; and the sheriff, in his official capacity, is an arm of the State entitled to Eleventh Amendment immunity. Date: 2005-02-24 Tags: legal,conditions Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Caldwell v. Warden: substantial-risk element uses objective standard In Caldwell v. Warden, FCI Talladega, the Eleventh Circuit stated that when examining the substantial-risk-of-serious-harm element, the court uses an objective standard, citing Marsh v. Butler County as abrogated on other grounds by Bell Atlantic Corp. v. Twombly. Date: 2014-04-07 Tags: legal,conditions Sources: Trevis Caldwell v. Warden, FCI Talladega, U.S. Court of Appeals, 11th Circuit, 2014-04-07 (court record via CourtListener) - [confirmed] Automatic stay of prospective relief upon termination motion Any motion to modify or terminate prospective relief made under subsection (b) shall operate as a stay beginning on the 30th day after such motion is filed, in the case of a motion made under paragraph (1) or (2) of subsection (b), or beginning on the 180th day after such motion is filed in the case of a motion made under any other law, ending on the date the court enters a final order ruling on the motion. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Thomas v. Bryant: repeated chemical-agent sprayings of mentally ill inmate violated Eighth Amendment In Thomas v. Bryant, the Eleventh Circuit affirmed the district court's conclusion that repeated non-spontaneous chemical-agent sprayings of a mentally ill inmate on a close-management wing violated the Eighth Amendment, finding no error in the district court's conclusions of law and its narrowly tailored injunction. Date: 2010-08-20 Tags: legal,mental_health,solitary,violence Sources: Thomas v. Bryant, U.S. Court of Appeals, 11th Circuit, 2010-08-20 (court record via CourtListener) - [confirmed] Diet 'grue' tolerable only briefly The Court stated that a diet described as 'grue' might be tolerable for a few days and intolerably cruel for weeks or months. Tags: legal,conditions Sources: October Term, 1977 - [confirmed] Ross v. Blake: no unwritten special circumstances exception to PLRA exhaustion Courts may not create an unwritten 'special circumstances' exception to the PLRA's exhaustion requirement; the only textual limit is that an inmate need exhaust only administrative remedies that are 'available.' Date: 2016-06-06 Tags: legal,policy Sources: Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener) - [confirmed] Marbury: officials need details showing strong likelihood of injury The Eleventh Circuit held that officials must possess enough details about a threat to conclude it presents a strong likelihood of injury, not a mere possibility. Date: 2019-08-29 Tags: legal,violence Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [reported] Richardson v. Johnson restates Chandler v. Crosby two-part Eighth Amendment conditions test The Eleventh Circuit in Richardson v. Johnson restated Chandler v. Crosby's two-part Eighth Amendment conditions test: under the objective component a prisoner must allege a prison condition so extreme that it poses an unreasonable risk of serious damage to the prisoner's health or safety, and under the subjective component the prisoner must allege the official acted with deliberate indifference, which has three components: subjective knowledge of a risk of serious harm, disregard of that risk, and conduct that is more than mere negligence. Date: 2010-03-02 Tags: legal,conditions Sources: Richardson v. Johnson, Court of Appeals for the Eleventh Circuit, 2010-03-02 (court record via CourtListener) - [confirmed] Wilson v. Seiter: conditions may violate Eighth Amendment in combination with mutually enforcing effect Wilson v. Seiter held that some conditions of confinement may establish an Eighth Amendment violation in combination when each would not do so alone, but only when they have a mutually enforcing effect that produces the deprivation of a single, identifiable human need such as food, warmth, or exercise, for example, a low cell temperature at night combined with a failure to issue blankets. Date: 1991-01-01 Tags: legal,conditions Sources: Wilson v. Seiter | 501 U.S. 294 (1991) | Justia U.S. Supreme Court Center - [confirmed] Newman v. Alabama: states must furnish basic necessities regardless of legislative inaction In Newman v. Alabama, the former Fifth Circuit held that prison authorities must furnish prisoners with reasonably adequate food, clothing, shelter, sanitation, and necessary medical attention, and that this obligation may not be frustrated by legislative inaction or failure to provide funds. Date: 1977-01-01 Tags: legal,conditions,medical Sources: Newman v. Alabama, U.S. Court of Appeals, 5th Circuit, 1977-09-16 (court record via CourtListener) - [confirmed] Brown v. Plata: no efficacious remedy without population reduction The Supreme Court held that without a reduction in overcrowding, there would be no efficacious remedy for the unconstitutional medical and mental health care in California's prisons, affirming the three-judge court's finding that no other relief would remedy the violation of the Federal right. Tags: legal,medical,mental_health,conditions Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Dukes: Rule 23(b)(2) requires indivisible injunctive remedy Dukes held that the key to a Rule 23(b)(2) class is the indivisible nature of the injunctive or declaratory remedy warranted, that the conduct can be enjoined or declared unlawful only as to all class members or none, and that Rule 23(b)(2) applies only when a single injunction or declaratory judgment would provide relief to each member, not when each member would be entitled to a different injunction or declaratory judgment. Date: 2017-08-18 Tags: legal Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [confirmed] Special master appointment in prison-conditions actions In any civil action in a Federal court with respect to prison conditions, the court may appoint a special master who shall be disinterested and objective and who will give due regard to the public safety, to conduct hearings on the record and prepare proposed findings of fact, and the court shall appoint a special master only during the remedial phase of the action upon a finding that the remedial phase will be sufficiently complex to warrant the appointment. Tags: legal,policy,conditions Sources: § 3626 Title 18—CRIMES and Criminal Procedure Page 848 - [confirmed] Thomas v. Bryant: three distinct categories of Eighth Amendment prison claims Thomas v. Bryant states that in the prison context, the Eighth Amendment gives rise to three distinct categories of claims -- conditions of confinement, excessive use of force, and deliberate indifference to serious medical needs -- each requiring a different showing to establish a constitutional violation. Date: 2010-08-20 Tags: legal,conditions,medical,violence Sources: Thomas v. Bryant, U.S. Court of Appeals, 11th Circuit, 2010-08-20 (court record via CourtListener) - [confirmed] 30-day isolation limitation upheld as part of remedy The Supreme Court held that the District Court did not err in including the 30-day limitation on sentences to isolation as part of its comprehensive remedy to correct the constitutional violations, because where the question before the court was whether past constitutional violations had been remedied, it was entitled to consider the severity of the violations in assessing the constitutionality of conditions in the isolation cells, the length of time each inmate spent in isolation being simply one consideration among many. Tags: legal,solitary,conditions Sources: October Term, 1977 - [reported] Marbury followed Purcell v. Toombs County Marbury v. Warden (11th Cir.) followed Purcell v. Toombs County (11th Cir.) in its analysis. Date: 2019-08-29 Tags: legal Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [confirmed] Rhodes v. Chapman: conditions alone or in combination may deprive inmates of minimal civilized measure of life's necessities Rhodes v. Chapman stated that conditions other than those in Estelle v. Gamble and Hutto v. Finney, alone or in combination, may deprive inmates of the minimal civilized measure of life's necessities, and such conditions could be cruel and unusual under the contemporary standard of decency. Date: 1981-01-01 Tags: legal,conditions Sources: Rhodes v. Chapman | 452 U.S. 337 (1981) | Justia U.S. Supreme Court Center - [confirmed] Newman v. Alabama: State conceded overcrowding and insufficient guards In Newman v. Alabama, the former Fifth Circuit affirmed, with some modifications, the remedies prescribed by the district court in Pugh v. Locke for eradicating cruel and unusual punishment in the Alabama prison system, after the State conceded excessive overcrowding, insufficient guards to reasonably protect inmates from one another, and that overcrowding was primarily responsible for and exacerbated all the other ills of the penal system. Date: 1977-01-01 Tags: legal,conditions,staffing,violence Sources: Newman v. Alabama, U.S. Court of Appeals, 5th Circuit, 1977-09-16 (court record via CourtListener) - [confirmed] Brown v. Plata affirmed population cap order The Supreme Court affirmed the three-judge court's PLRA prisoner release order capping California's prison population, holding that the order was required by the Eighth Amendment to remedy ongoing medical and mental-health care violations and was authorized by the PLRA. Tags: legal,medical,mental_health,conditions Sources: Brown v. Plata, 09 1233.ZO - [confirmed] Fifth Circuit three requirements for Rule 23(b)(2) certification In the Pack Unit heat-conditions class decision, the Fifth Circuit held that Rule 23(b)(2) certification requires common behavior by the defendant toward the class and is available if three requirements are satisfied: (1) class members must have been harmed in essentially the same way; (2) injunctive relief must predominate over monetary damage claims; and (3) the injunctive relief sought must be specific. Date: 2017-08-18 Tags: legal Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [confirmed] DOJ investigation conducted under CRIPA 'pattern or practice' authority The DOJ press release states that under CRIPA, the department has authority to investigate whether any violations of prisoners' constitutional rights result from a 'pattern or practice of resistance to the full enjoyment of such rights,' and that the investigation was conducted under the Civil Rights of Institutionalized Persons Act. Date: 2021-09-14 Tags: legal,investigations Sources: DOJ Press Release: Justice Department Announces Investigation into Conditions in Georgia Prisons - [confirmed] Brooks v. Warden: well established right to basic sanitation Brooks v. Warden holds that the Eleventh Circuit and the former Fifth Circuit have long recognized a well established Eighth Amendment right not to be confined in conditions lacking basic sanitation, citing Chandler v. Baird. Date: 2015-09-03 Tags: legal,conditions Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Swain v. Junior: COVID-19 injunction vacated for lack of subjective recklessness In Swain v. Junior, the Eleventh Circuit vacated a preliminary injunction that had ordered a Miami jail to take COVID-19 precautions, holding that the district court erred in concluding the defendants acted with deliberate indifference where the court itself found that the defendants' notice of compliance showed they had provided cleaning and hygiene supplies, masks, and other measures, and that failing to achieve impossible six-foot social distancing did not establish a culpable state of mind. Date: 2020-06-15 Tags: legal,medical,conditions Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [confirmed] Miller v. French: 18 U.S.C. § 3626(e) automatic-stay provision does not violate separation of powers Miller v. French held that Section 3626(e) of Title 18 does not violate separation of powers principles. Date: 2000-01-01 Tags: legal,policy Sources: Miller v. French | 530 U.S. 327 (2000) | Justia U.S. Supreme Court Center - [confirmed] Newman v. Alabama: remedial decree affirmed with modifications The former Fifth Circuit affirmed, with modifications, the district court's remedial decree for the Alabama prison system: steps to ensure reasonably adequate food, clothing, shelter, sanitation, medical attention and personal safety were within the court's discretion; the oversight committee had to be replaced by monitors, and the visitation, Governor and other provisions were modified. Date: 1977-01-01 Tags: legal,conditions Sources: Newman v. Alabama, U.S. Court of Appeals, 5th Circuit, 1977-09-16 (court record via CourtListener) - [confirmed] Bonner v. City of Prichard adopted former Fifth Circuit precedent Brooks v. Warden states that in Bonner v. City of Prichard the Eleventh Circuit, sitting en banc, adopted as binding precedent all decisions of the former Fifth Circuit handed down prior to October 1, 1981. Date: 1981-10-01 Tags: legal Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] PLRA definition of prisoner release order The PLRA defines 'prisoner release order' as any order, including a TRO or preliminary injunctive relief, that has the purpose or effect of reducing or limiting the prison population, or that directs the release from or nonadmission of prisoners to a prison (18 U.S.C. § 3626(g)(4)). Date: 2016-03-04 Tags: legal,policy Sources: Gillette v. Prosper, District Court, Virgin Islands, 2016-03-04 (court record via CourtListener) - [confirmed] Woodford v. Ngo: proper exhaustion demands compliance with agency deadlines and procedural rules Woodford v. Ngo states that proper exhaustion demands compliance with an agency's deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings. Date: 2006-06-22 Tags: legal,policy Sources: Woodford v. Ngo, Supreme Court of the United States, 2006-06-22 (court record via CourtListener) - [confirmed] Harper v. Bennett Consent Order December 21, 2005 set staffing and population limits On December 21, 2005, the court in Harper v. Bennett entered a Consent Order providing the terms and conditions necessary to ensure constitutional compliance by the jail, setting minimum staffing levels, staff training procedures, inmate population limits, and inmate processing requirements. Date: 2005-12-21 Tags: legal,staffing,conditions Sources: Harper v. Bennett 1:04-cv-01416 (N.D. Ga.) | Civil Rights Litigation Clearinghouse - [reported] Lane v. Philbin followed Chandler v. Crosby on future-health-risk standard Later treatment: Lane v. Philbin (11th Cir.) followed Chandler v. Crosby (11th Cir.) regarding risk to future health or safety. Date: 2016-08-26 Tags: legal Sources: Rodney Manyon Lane v. Ted Philbin, Court of Appeals for the Eleventh Circuit, 2016-08-26 (court record via CourtListener) - [confirmed] DOJ notified Georgia of intent to investigate juvenile facilities March 3, 1997 On March 3, 1997, the United States notified Governor Zell Miller and other Georgia officials of its intent to investigate various juvenile facilities in the State of Georgia under the Civil Rights of Institutionalized Persons Act, 42 U.S.C. § 1997a, et seq., and the pattern or practice provision. Date: 1997-03-03 Tags: legal,investigations,facilities Sources: Civil Rights Division | Georgia Juvenile Facilities Memorandum Agreement - [reported] Peralta v. Dillard (en banc) explained LaMarca v. Turner on official-capacity injunctive relief Later treatment: Peralta v. Dillard (9th Cir. en banc) explained LaMarca v. Turner (11th Cir.), which held that a prison official would not be personally liable if he did everything he could, but the prisoner could get an injunction against the official in his official capacity. Date: 2014-03-06 Tags: legal Sources: Cion Peralta v. T. Dillard, Court of Appeals for the Ninth Circuit, 2014-03-06 (court record via CourtListener) - [confirmed] DOJ juvenile facilities findings letter February 13, 1998 led to Memorandum of Agreement On February 13, 1998, the United States issued a findings letter concluding that certain conditions in Georgia's juvenile justice facilities allegedly violated particular constitutional and federal statutory rights, and the parties entered a Memorandum of Agreement to resolve the matter. Date: 1998-02-13 Tags: legal,conditions,facilities Sources: Civil Rights Division | Georgia Juvenile Facilities Memorandum Agreement CASE DETAILS (51) ---------------------------------------- - [reported] Chandler v. Baird alleged conditions: cold cell, no bedding, no toilet paper or running water In Chandler v. Baird, the plaintiff alleged Eighth Amendment violations consisting of confinement in a cold cell with no clothes except undershorts and a plastic-covered mattress without bedding; filth on the cell's floor and walls; deprivation of toilet paper for three days; deprivation of running water for two days; lack of soap, toothbrush, toothpaste, and linen; and prior occupancy of the cell by an inmate afflicted with HIV. The temperature was alleged to be as low as 60 degrees. Date: 1991-03-15 Tags: conditions,legal,facilities Sources: Chandler v. Baird, U.S. Court of Appeals, 11th Circuit, 1991-03-15 (court record via CourtListener) - [reported] DOJ: August 2021 sexual assault reported at Valdosta State Prison The DOJ findings report states that in August 2021, a man at Valdosta State Prison reported that another incarcerated person choked him and forcibly penetrated his mouth in the cell where the man had been sleeping, which was not his assigned cell. Date: 2021-08-01 Tags: violence,facilities,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] DOJ Fulton County Jail investigation initiated July 2023 The Justice Department initiated its investigation of the Fulton County Jail in July 2023, proceeding under the Civil Rights of Institutionalized Persons Act (CRIPA), the Americans with Disabilities Act, and the Violent Crime Control and Law Enforcement Act of 1994. Date: 2023-07-01 Tags: investigations,legal,conditions,facilities Sources: Justice Department Reaches Proposed Consent Decree with Fulton County, U.S. DOJ - [reported] $350,000 settlement for prisoner murdered at Hays State Prison GDC agreed to pay $350,000 to settle a civil rights action filed by the estate of a prisoner murdered at Hays State Prison, following a 2012-2013 period in which four Hays prisoners were killed over a five-week period. Tags: violence,death,legal,facilities Sources: $350,000 Settlement for Estate of Prisoner Murdered at Georgia Prison - [confirmed] Swain v. Junior: class action by medically vulnerable pretrial detainees In Swain v. Junior, medically vulnerable pretrial detainees at Metro West Detention Center in Miami filed a class-action complaint against Miami-Dade County and the corrections director, seeking to represent themselves, a class of all current and future persons detained at Metro West during the pandemic, and a subclass of medically vulnerable detainees, alleging Eighth and Fourteenth Amendment deliberate-indifference claims regarding COVID-19 and seeking declaratory and injunctive relief under 42 U.S.C. § 1983. Date: 2020-06-15 Tags: legal,medical,conditions Sources: Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener) - [reported] Laube v. Haley: converted storage-room 'holding cell' held up to four inmates for 24 hours to a week In Laube v. Haley, the district court found as fact that Birmingham's segregation cell, called the 'holding cell,' could hold up to four inmates who may remain there anywhere from 24 hours to a week, was not initially designed to be used as a segregation unit but was a storage room converted to hold inmates, and that the cell was very hot with no window and no moving air inside it except a fan outside the cell. Date: 2002-12-02 Tags: conditions,solitary,facilities,legal Sources: Laube v. Haley, 2002-12-02 (court record via CourtListener) - [confirmed] Lane v. Philbin: Valdosta State Prison allegations of gang violence and inadequate supervision In Lane v. Philbin, the Eleventh Circuit held that a Valdosta State Prison inmate's pro se complaint sufficiently alleged a substantial risk of serious harm where it alleged that one officer supervised two 50-man dormitories housing 90% gang-affiliated inmates, that numerous stabbings and beatings occurred, and that inmates fashioned weapons from maintenance materials and light fixtures that were not confiscated despite searches. Date: 2016-08-26 Tags: legal,violence,gangs,staffing,facilities Sources: Rodney Manyon Lane v. Ted Philbin, U.S. Court of Appeals, 11th Circuit, 2016-08-26 (court record via CourtListener) - [confirmed] Gumm v. Jacobs filed pro se February 12, 2015 over solitary confinement On February 12, 2015, a prisoner at Georgia Diagnostic and Classification Prison filed the Gumm v. Jacobs lawsuit pro se, claiming that holding him in solitary confinement violated his Fourteenth Amendment rights to procedural and substantive due process. Date: 2015-02-12 Tags: solitary,legal,conditions Sources: Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile - [confirmed] Turner v. Burnside: dismissal vacated on disputed facts Because facts were disputed (whether the warden tore up the grievance and made the threat), the dismissal was vacated and the case remanded. Date: 2008-08-28 Tags: legal Sources: Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener) - [confirmed] Gumm v. Jacobs amended complaint sought class certification for SMU On March 11, 2017, the plaintiff in Gumm v. Jacobs filed an amended complaint represented by counsel from the Southern Center for Human Rights, greatly expanding the scope of the case by seeking class certification covering everyone in the SMU. Date: 2017-03-11 Tags: solitary,legal Sources: Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile - [reported] DOJ seeks summary judgment in United States v. Alabama prison violence case Federal prosecutors filed a heavily redacted motion for summary judgment ahead of a scheduled November trial over whether violence in Alabama's prisons violates inmates' Eighth Amendment protections against cruel and unusual punishment. Tags: legal,violence,investigations Sources: Federal government seeks summary judgment against Alabama Department of Corrections | Alabama Reflector - [confirmed] Gumm v. Jacobs settlement proposed out-of-cell time improvements On December 21, 2018, the parties in Gumm v. Jacobs filed a joint motion for preliminary approval of the class and a settlement agreement proposing measures to improve confinement conditions at GDCP, including regular opportunities for outdoor and indoor out-of-cell time. Date: 2018-12-21 Tags: solitary,legal,conditions Sources: Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile - [reported] Guthrie v. Evans filing and closing dates The Civil Rights Litigation Clearinghouse lists Guthrie v. Evans (1:73-cv-03068, S.D. Ga.) as filed Sept. 1, 1972 and closed April 24, 1987. Tags: legal,conditions Sources: Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page - [confirmed] Taylor v. Riojas: inmate moved to frigid cell with only clogged floor drain for bodily wastes In Taylor v. Riojas, the Court described that correctional officers moved the inmate to a second, frigidly cold cell, which was equipped with only a clogged drain in the floor to dispose of bodily wastes. Date: 2020-01-01 Tags: conditions,legal,facilities Sources: Cite as: 592 U. S. ____ (2020) 1 - [confirmed] Hale appeal outcome: affirmed as to jailer, reversed as to sheriff and county On appeal from summary judgment for jail defendants in a detainee's inmate-beating § 1983 suit, the Eleventh Circuit affirmed as to the jailer but reversed as to the sheriff and county, holding the detainee's evidence (regular violence during overcrowding, the sheriff's knowledge of it, and his failure to classify, assign, train or supervise) was sufficient for a jury on substantial risk, deliberate indifference and causation. Date: 1995-05-02 Tags: legal,violence Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Judge Treadwell granted preliminary approval of Gumm settlement January 17, 2019 On January 17, 2019, Judge Treadwell granted preliminary approval of the settlement in Gumm v. Jacobs, and on February 5, 2019 denied the pending motions for preliminary injunction and class certification because final approval of the settlement was pending. Date: 2019-01-17 Tags: solitary,legal Sources: Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile - [reported] Marsh v. Butler County: nonworking cell locks prevented guards from locking down prisoners In Marsh v. Butler County, evidence showed that locks to the doors of the inmates' cells did not work, resulting in the inability of the guards to lock down the prisoners. Date: 2001-09-26 Tags: conditions,facilities,violence,legal Sources: Marsh v. Butler County, U.S. Court of Appeals, 11th Circuit, 2001-09-26 (court record via CourtListener) - [reported] Cason v. Seckinger filed July 13, 1984 and closed February 25, 2002 The Civil Rights Litigation Clearinghouse lists Cason v. Seckinger (5:84-cv-00313, M.D. Ga.) with a filing date of July 13, 1984 and a closing date of February 25, 2002. Tags: legal,conditions,facilities Sources: Cason v. Seckinger 5:84-cv-00313 (M.D. Ga.) | Civil Rights Litigation Clearinghouse - [confirmed] Gumm v. Jacobs closed May 22, 2025 The Civil Rights Litigation Clearinghouse lists Gumm v. Jacobs with a Filing Date of Feb. 12, 2015 and a Closing Date of May 22, 2025. Date: 2025-05-22 Tags: solitary,legal Sources: Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile - [reported] Marsh v. Butler County: no headcounts and often a single jailer on duty In Marsh v. Butler County, evidence showed that jailers never conducted prisoner headcounts and that often only one jailer was on duty at the jail at a time, that single jailer being responsible for controlling the entire inmate population. Date: 2001-09-26 Tags: staffing,conditions,operations,legal Sources: Marsh v. Butler County, U.S. Court of Appeals, 11th Circuit, 2001-09-26 (court record via CourtListener) - [reported] DOJ filed summary judgment motion in Alabama prison-conditions case on September 2, 2026 The United States filed a Motion for Summary Judgment in United States v. State of Alabama and Alabama Department of Corrections, Civil No. 2:20-cv-01971-HDM (N.D. Ala. Southern Division), with the document filed and stamped by the court on September 2, 2026 (Document 378, 260 pages). Date: 2026-09-02 Tags: legal,conditions,investigations Sources: Case 2:20-cv-01971-HDM Document 378 Filed 09/02/26 Page 1 of 260 FILED - [confirmed] Benning v. Oliver motion to enforce granted February 10, 2026 On February 10, 2026, the court held a hearing in Benning v. Oliver on plaintiff's motion to enforce, attended by plaintiff pro se and defendant Tyrone Oliver, Commissioner for the Georgia Department of Corrections, along with his counsel, after which the court granted plaintiff's motion to enforce. Date: 2026-02-10 Tags: legal,policy Sources: Court record, M.D. Ga., 2026-02-10 (court record via CourtListener) - [reported] Fambro: Fulton County jail in violation of consent decree In Fambro v. Fulton County, the district court found the jail had been under a consent decree for five years and that within ninety days of entering the decree Fulton County was in violation to major or minor extents and had been at all times since. Date: 1989-04-21 Tags: legal,conditions,facilities Sources: Fambro v. Fulton County, Ga., N.D. Ga., 1989-04-21 (court record via CourtListener) - [reported] Anderson v. Nosser: Parchman demonstrators held up to eight per cell without bedding, soap, or towels In Anderson v. Nosser, the former Fifth Circuit found that Natchez civil-rights demonstrators transferred to Parchman's maximum security unit were held up to eight persons per cell containing two steel bunks without mattresses or bedding, a toilet without a seat, and a washbasin with no towels or soap and inadequate toilet paper, at temperatures ranging from 60 to 70 degrees aggravated by intermittently blowing exhaust fans, with some men left nude for 36 hours. Date: 1971-05-27 Tags: conditions,legal,facilities Sources: Katie Ruth Anderson v. J. J. Nosser, James Bradley v. J. J. Nosser, U.S. Court of Appeals, 5th Circuit, 1971-05-27 (court record via CourtListener) - [confirmed] Taylor v. Riojas: six days in shockingly unsanitary cells Taylor alleged that for six full days in September 2013, correctional officers confined him in a pair of shockingly unsanitary cells, the first covered nearly floor to ceiling in massive amounts of feces including inside the water faucet, and the second a frigidly cold cell equipped with only a clogged drain, where he was confined without clothing and left to sleep naked in sewage after the drain overflowed. Date: 2013-09-01 Tags: conditions,legal Sources: Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener) - [reported] Harper v. Bennett: class certification motion filed in Fulton County Jail conditions case In Harper v. Bennett (Fulton County Jail conditions litigation), plaintiffs filed a motion for class certification with a supporting memorandum, entered on the docket on June 28, 2004. Date: 2004-06-28 Tags: legal,conditions,facilities Sources: Harper v. Bennet, 2004-06-25 (court record via CourtListener) - [confirmed] Benning v. Oliver Order to Show Cause issued December 19, 2025 On December 19, 2025, the court in Benning v. Oliver issued an Order to Show Cause ordering defendants to explain why plaintiff's requested relief should not be granted, and defendants responded January 2, 2026. Date: 2025-12-19 Tags: legal Sources: Court record, M.D. Ga., 2026-02-10 (court record via CourtListener) - [confirmed] Hoffer v. Jones: class certified for prisoners with chronic HCV In Hoffer v. Jones, plaintiffs moved to certify a class of 'all current and future prisoners in FDC custody who have been diagnosed, or will be diagnosed, with chronic hepatitis C virus (HCV),' and the court had already granted the motion for class certification. Date: 2017-11-17 Tags: legal,medical Sources: Hoffer v. Jones, 2017-11-17 (court record via CourtListener) - [confirmed] Marsh v. Butler County allegations included routine understaffing and no head counts In Marsh v. Butler County, as quoted by the Eleventh Circuit in Mosley v. Zachery, the plaintiffs alleged among the jail conditions creating a substantial risk of serious harm that the Jail was routinely understaffed and that no head counts of prisoners were made to make sure they were all accounted for. Date: 2001-01-01 Tags: staffing,conditions,legal Sources: Tommy L. Mosley, Jr. v. Lt. Towanda Zachery, U.S. Court of Appeals, 11th Circuit, 2020-07-24 (court record via CourtListener) - [confirmed] Chandler v. Crosby: bench trial and March 24, 2003 order denying relief The Eleventh Circuit in Chandler v. Crosby reviewed the case after the district court convened a bench trial and, on March 24, 2003, issued an order denying relief on the merits, which the inmates then appealed. Date: 2003-03-24 Tags: legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Court cited contempt order against GDC in Daughtry v. Emmons At the hearing in Benning v. Oliver, the court discussed a contempt order filed against GDC by another judge of the same court, citing Daughtry v. Emmons, No. 5:15-CV-41 (MTT), 2024 WL 1791717 (M.D. Ga. Apr. 23, 2024). Date: 2024-04-23 Tags: legal,corruption Sources: Court record, M.D. Ga., 2026-02-10 (court record via CourtListener) - [reported] Chandler v. Baird conditions alleged: cold cell, no bedding, no water In Chandler v. Baird, the plaintiff alleged confinement in a cold cell with no clothes except undershorts and a plastic-covered mattress without bedding; filth on the cell's floor and walls; deprivation of toilet paper for three days; deprivation of running water for two days; lack of soap, toothbrush, toothpaste, and linen; and earlier occupancy of the cell by an inmate afflicted with HIV, with cell temperature as low as 60 degrees. Date: 1991-03-15 Tags: conditions,legal,medical Sources: Jim Eric Chandler v. Captain William Baird, U.S. Court of Appeals, 11th Circuit, 1991-03-15 (court record via CourtListener) - [confirmed] Marsh v. Butler County: jail administrator and state inspector warned of staffing and security In Marsh v. Butler County, as quoted by the Eleventh Circuit in Mosley v. Zachery, the jail administrator told the sheriff several times that the jail needed more staff, and the jail inspector for the Alabama Department of Corrections informed defendants that the jail was not reasonably secure. Date: 2001-01-01 Tags: staffing,conditions,legal Sources: Tommy L. Mosley, Jr. v. Lt. Towanda Zachery, U.S. Court of Appeals, 11th Circuit, 2020-07-24 (court record via CourtListener) - [confirmed] Chandler v. Crosby: class certified under Rule 23(b)(2) for Northeast Unit In Chandler v. Crosby, the district court certified, pursuant to Rule 23(b)(2) of the Federal Rules of Civil Procedure, a class consisting of all persons who were currently assigned to the Northeast Unit at Union Correctional Institution or who in the future would be assigned to that housing unit. Date: 2000-12-04 Tags: legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Cason v. Seckinger filed July 13, 1984 GDC's FY1992 annual report states that on July 13, 1984 the Cason v. Seckinger civil rights class action lawsuit was filed against GDC and a number of its employees and officials in the U.S. District Court for the Middle District of Georgia, Macon Division, brought by Georgia Legal Services, focused on GDC facilities in the Milledgeville area known as the Middle Georgia Correctional Complex. Date: 1984-07-13 Tags: legal,conditions,facilities Sources: 1992 annual report - [confirmed] Alabama and ADOC moved for summary judgment in United States v. State of Alabama (Aug. 31, 2026) In United States v. State of Alabama (N.D. Ala.), the Alabama Department of Corrections and the State of Alabama filed a Motion for Summary Judgment, with a USB drive received in the Huntsville Clerk's Office on 8/31/2026. Date: 2026-08-31 Tags: legal,investigations Sources: United States v. State of Alabama, 2026-08-31 (court record via CourtListener) - [confirmed] GWCI staff misconduct allegations reported to Attorney General February 28, 1992 GDC's FY1992 annual report states that on February 28, 1992 Georgia Legal Services reported to the Attorney General's Office a series of allegations of staff misconduct made by Georgia Women's Correctional Institution inmates, including coerced abortions, sexual harassment, physical abuse, and sexual contact, and that the next business day Commissioner Bobby K. Whitworth requested a GBI investigation into the allegations. Date: 1992-02-28 Tags: corruption,violence,investigations,facilities Sources: 1992 annual report - [confirmed] Hope v. Pelzer: hitching-post facts In 1995, Hope, then an Alabama prison inmate, was twice handcuffed to a hitching post for disruptive conduct. After a June altercation with a guard, he was subdued, handcuffed, placed in leg irons, ordered to take off his shirt exposing himself to the sun, and spent seven hours on the hitching post, where he was given one or two water breaks but no bathroom breaks, and a guard taunted him about his thirst. Date: 1995-01-01 Tags: conditions,legal Sources: October Term, 2001 - [reported] Jordan v. Doe: overcrowding and 24-hour lighting at Hillsborough County jail In Jordan v. Doe, the plaintiff's affidavit stated that the Hillsborough County jail kept the lights on 24 hours a day in his housing area and the television going 24 hours a day, with roaches overrunning the area, and that between 28 and 30 men were held in a 16-man tank so overcrowded it was wall to wall mattresses. Date: 1994-12-02 Tags: conditions,facilities Sources: Jordan v. Doe, U.S. Court of Appeals, 11th Circuit, 1994-12-02 (court record via CourtListener) - [confirmed] DOJ announced Georgia prisons findings October 1, 2024 On October 1, 2024, DOJ's Civil Rights Division and the U.S. Attorney's Offices for the Northern, Middle, and Southern Districts of Georgia announced findings from a civil rights investigation of Georgia prisons. Date: 2024-10-01 Tags: investigations,legal,conditions Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024); Georgia Prisons Investigation Findings - [confirmed] Alabama and ADOC moved to consider post-discovery evidence and modify August 31, 2026 order In United States v. State of Alabama (N.D. Ala.), the Alabama Department of Corrections and State of Alabama filed a Motion to Consider Post-Discovery Evidence in Opposition to Plaintiff's Motion for Summary Judgment and, to the extent necessary, for limited modification of the court's August 31, 2026 order. Date: 2026-01-01 Tags: legal Sources: United States v. State of Alabama, 2026-08-31 (court record via CourtListener) - [confirmed] DOJ investigation opened 2016 on LGBTI sexual abuse, expanded 2021 to violence DOJ opened a statewide investigation in 2016 into whether GDC adequately protects LGBTI incarcerated persons from sexual abuse by staff and other incarcerated persons, and expanded it in 2021 to include protection of all incarcerated persons at medium- and close-security prisons from violence. Tags: investigations,violence,conditions Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] Bowen v. Warden: officials knew cellmate was Level III mental health inmate In Bowen v. Warden, Baldwin State Prison, the evidence the court found sufficient to show subjective knowledge included that officials knew the cellmate had been designated a Level III mental health inmate, had committed a High-Assault without a weapon on a prior cellmate, and that under the prison's Placement Guidelines he was required to be housed alone, yet he was double-celled with the decedent under the warden's double-celling policy. Date: 2016-06-22 Tags: mental_health,violence,legal,facilities Sources: Bowen Ex Rel. Estate of Bowen v. Warden, Baldwin State Prison, U.S. Court of Appeals, 11th Circuit, 2016-06-22 (court record via CourtListener) - [confirmed] Dunn v. Dunn: settlement class of ADOC inmates with disabilities certified In Dunn v. Dunn, the M.D. Ala. district court certified a settlement class defined as 'any current or future inmate in the physical custody of ADOC who has a disability as defined in 42 U.S.C. § 12102 and 29 U.S.C. § 705(9)(B), excluding those inmates whose disabilities relate solely to or arise solely from mental disease, illness, or defect.' Date: 2016-09-09 Tags: legal,mental_health Sources: Dunn v. Dunn, 2016-09-09 (court record via CourtListener) - [confirmed] Foster v. Fulton County filed April 8, 1999 by HIV-positive inmates On April 8, 1999, inmates at the Fulton County Jail in Atlanta who had tested positive for HIV filed the Foster v. Fulton County class action lawsuit against county officials, represented by the Southern Center for Human Rights, in the U.S. District Court for the Northern District of Georgia. Date: 1999-04-08 Tags: legal,medical,conditions Sources: Foster v. Fulton County 1:99-cv-00900 (N.D. Ga.) | Civil Rights Litigation Clearinghouse - [confirmed] DOJ opened statewide civil investigation into Georgia prison conditions on September 14, 2021 The Justice Department announced on September 14, 2021 that it opened a statewide civil investigation into conditions of confinement of prisoners held in Georgia's prisons. Date: 2021-09-14 Tags: investigations,legal,conditions Sources: DOJ Press Release: Justice Department Announces Investigation into Conditions in Georgia Prisons - [confirmed] Foster v. Fulton County final order January 24, 2000 required improved medical care On January 24, 2000, the court in Foster v. Fulton County, after a hearing on the settlement, entered a final order and closed the case, requiring defendants to improve medical care. Date: 2000-01-24 Tags: legal,medical Sources: Foster v. Fulton County 1:99-cv-00900 (N.D. Ga.) | Civil Rights Litigation Clearinghouse - [reported] Brooks v. Warden: failure-to-protect claim dismissed, sanitation claim revived In Brooks v. Warden, the Eleventh Circuit affirmed dismissal of the plaintiff's failure-to-protect claim arising from a prison riot, but reversed the dismissal of his Eighth Amendment claim that he was forced to defecate in his jumpsuit and sit in his own excrement for two days while restrained in a hospital bed, holding the deputy warden was not entitled to qualified immunity. Date: 2015-09-03 Tags: conditions,legal,violence,medical Sources: Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener) - [confirmed] Harper v. Bennett filed May 19, 2004 against Fulton County and GDC On May 19, 2004, inmates at the Fulton County Jail filed the Harper v. Bennett lawsuit in the U.S. District Court for the Northern District of Georgia against Fulton County and the Georgia Department of Corrections under 42 U.S.C. 1983, challenging the conditions of their confinement. Date: 2004-05-19 Tags: legal,conditions Sources: Harper v. Bennett 1:04-cv-01416 (N.D. Ga.) | Civil Rights Litigation Clearinghouse - [confirmed] Marbury: summary judgment affirmed for warden and officer Affirming summary judgment, the Eleventh Circuit held a prisoner's sparse evidence (his own statement of witnessing fifteen stabbings, without context) did not show a generalized risk of violence so pervasive as to be a substantial risk of serious harm, and his vague report of a threat from an unnamed prisoner did not give officials enough detail to know of a strong likelihood of injury. Date: 2019-08-29 Tags: legal,violence Sources: Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener) - [confirmed] Receiver appointed in Harper v. Bennett July 14, 2004 Pursuant to a Consent Order of the District Court on July 7, 2004 in Harper v. Bennett, the parties agreed to the appointment of a Receiver by the court, and on July 14 the court appointed a Receiver. Date: 2004-07-14 Tags: legal,operations Sources: Harper v. Bennett 1:04-cv-01416 (N.D. Ga.) | Civil Rights Litigation Clearinghouse POLICYS (11) ---------------------------------------- - [confirmed] GDC grievance filing deadline: 10 calendar days GDC's Statewide Grievance Procedure (SOP 227.02) requires that a grievance complaint be a single issue/incident and be submitted no later than ten calendar days from the date the offender knew, or should have known, of the facts giving rise to the grievance; later grievances may only be considered upon good cause. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [confirmed] GDC Central Office Appeal deadline: 7 calendar days Under SOP 227.02, the offender has seven calendar days from the Warden's response date to file a Central Office Appeal; the Grievance Coordinator or Commissioner's Designee may waive this time limit for good cause. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [reported] GDC grievance procedures arose from Guthrie court order A Georgia Prisons report states that new grievance procedures included in GDC's inmate handbook were developed as part of the court order in the Guthrie v. MacDougall suit. Tags: policy,legal,conditions Sources: Georgia Prisons - [confirmed] Emergency grievance: Duty Officer must act immediately, respond within 48 hours SOP 227.02 requires that when a complaint is determined to be an Emergency Grievance, the Duty Officer must immediately take whatever action is necessary to protect the health, safety, or welfare of the offender and provide an initial response within 48 hours. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [confirmed] GDC grievance scope limited to issues personally affecting the offender SOP 227.02 allows an offender to grieve any condition, policy, procedure, or action or lack thereof that personally affects the offender, and lists as non-grievable matters that do not personally affect the offender. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [reported] DOJ remedial measure: quality assurance with morbidity/mortality reviews The DOJ report's minimum remedial measures include implementing a quality assurance program with complete, interdisciplinary morbidity/mortality reviews of all deaths, attempted suicides, and other critical incidents; adequately maintained; examining for patterns and trends; and identifying and correcting systemic deficiencies. Date: 2024-01-01 Tags: death,medical,mental_health,policy,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [confirmed] SOP 227.02 authority includes GDC Board Rule 125-2-4-.23 SOP 227.02 states that its authority includes GDC Board Rules 125-2-4-.23. Tags: legal,policy Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [confirmed] Warden grievance decision deadline: 40 calendar days plus one 10-day extension SOP 227.02 provides that the Warden or Superintendent has forty calendar days from the date the offender submitted the grievance form to deliver a decision, with a one-time ten-calendar-day extension available if the offender is advised in writing or via kiosk/tablet before the original 40 days expire. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [confirmed] Commissioner decision deadline on Central Office Appeal: 120 calendar days SOP 227.02 provides that the Commissioner or the Commissioner's designee has 120 calendar days after submission of the Central Office Appeal Form to deliver a decision to the offender. Tags: legal,policy,operations Sources: SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019 - [confirmed] GDC Litigation Support unit assisted Cason v. Seckinger resolution in FY1994 GDC's FY1994 annual report states its Litigation Support unit helps provide information to GDC staff, legal counsel and others involved in the resolution of the Cason v. Seckinger litigation, which includes all inmates incarcerated in the Middle Georgia Correctional Complex and all female inmates and female probationers. Date: 1994-01-01 Tags: legal,operations Sources: 1994 annual report - [confirmed] GDC Compliance Section audited Cason v. Seckinger consent decree compliance in FY1994 GDC's FY1994 annual report states the Compliance Section performed operational audits based on the Cason v. Seckinger consent decree at the institutions covered by the decree. Date: 1994-01-01 Tags: legal,operations Sources: 1994 annual report FINDINGS (28) ---------------------------------------- - [reported] DOJ: GDC fails to protect incarcerated people from sexual abuse; LGBTI people especially vulnerable The DOJ findings report concluded that GDC fails to protect incarcerated persons from sexual abuse, that the lack of staffing, supervision, and systems of accountability gives predators easy access to potential victims, and that people who are LGBTI are especially vulnerable. Date: 2024-01-01 Tags: violence,staffing,conditions,investigations,legal Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] DOJ: seven 2022 deaths misclassified until 2024 The DOJ identified seven deaths from 2022 that GDC categorized as undetermined or natural until eventually categorizing them as homicides in 2024, although other official records made clear much earlier that the deaths were homicides. Tags: death,violence,investigations,data_gap Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [reported] DOJ findings report recommends 82 remedial measures for GDC DOJ's findings report recommends 82 remedial measures for GDC to implement 'at minimum,' addressing staffing, supervision, incident response, investigations, contraband, facility conditions, classification and housing, and sexual safety. Tags: legal,policy,staffing,contraband,conditions Sources: DOJ Investigation of Georgia Prisons, Civil Rights Litigation Clearinghouse - [confirmed] Braggs v. Dunn: Commissioner described 'two-headed monster' of overcrowding and understaffing In Braggs v. Dunn, Alabama prison Commissioner Jefferson Dunn testified that the prison system was wrestling with a 'two-headed monster': overcrowding and understaffing. Date: 2017-01-01 Tags: staffing,conditions,legal Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [reported] Southeastern states affected by federal court order or consent decree 1985-1993 The Georgia State Board of Pardons and Paroles' annual report for FY1992-1993 includes a chart titled 'SOUTHEASTERN STATES AFFECTED BY FEDERAL COURT ORDER OR CONSENT DECREE 1985-1993' and states that all of Georgia's neighboring states have been impacted by a federal court order or consent decree. Tags: legal,conditions,policy Sources: GEORGIA STATE BOARD OF PARDONS AND PAROLES: ANNUAL REPORT, JULY 1, 1992-JUNE 30, 1993 - [reported] Braggs Phase 2A: staffing deadline understood by both parties to require modification In the Phase 2A Omnibus Remedial Opinion in Braggs v. Dunn, the court stated that the February 2022 staffing deadline was one that both parties understood would have to be modified given ADOC's slow pace of progress in filling many of its correctional positions. Tags: staffing,legal Sources: Case 2:14-cv-00601-MHT-JTA Document 3461 Filed 12/27/21 Page 1 of 49 - [reported] DOJ excessive-force findings in 12 of 13 Alabama prisons DOJ found reasonable cause to believe that correctional officers within the Alabama Department of Corrections frequently use excessive force on prisoners, identifying frequent uses of excessive force in 12 of the 13 Alabama prisons reviewed, pursuant to a pattern or practice of resistance to Eighth Amendment rights. Tags: violence,investigations,legal Sources: U.S. Department of Justice, 1297026 - [confirmed] Braggs v. Dunn: both sides agreed staffing shortages plus overcrowding drive mental-health deficiencies In Braggs v. Dunn, fact witnesses and experts from both sides essentially agreed that staffing shortages, combined with persistent and significant overcrowding, contribute to serious systemic deficiencies in the delivery of mental-health care in Alabama's prisons. Date: 2017-01-01 Tags: staffing,mental_health,conditions,legal Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [reported] GDC entry listed as investigation case with no complaint or consent decree DOJ's Special Litigation Section 'Cases and Matters' tracker lists the Georgia Department of Corrections entry as an 'Investigation Case Summary' with only a Cover Letter, Findings Report, Findings Report Executive Summary, and Findings Report One Pager (all dated 2024), with no Complaint or Consent Decree listed, while a separate Fulton County Jail entry in the same Georgia section is listed as an 'Enforcement Case Summary' with a Notice Letter (2024), Findings Report (2024), Complaint (2025), and Consent Decree (2025). Tags: legal,investigations,policy Sources: Civil Rights Division | Special Litigation Section Cases and Matters - [confirmed] Braggs v. Dunn: expert called ADOC understaffing 'shocking' with cascading mental-health effects In Braggs v. Dunn, plaintiffs' correctional administration expert Eldon Vail testified that the level of correctional understaffing at ADOC was so low as to be 'shocking,' with cascading effects including inadequate staff to transport prisoners to appointments and supervise treatment activities, and inadequate staff to monitor segregation inmates who have higher suicide risks. Date: 2017-01-01 Tags: staffing,mental_health,solitary,legal Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [confirmed] Braggs v. Dunn: defense expert doubted policy compliance due to understaffing and missing documentation In Braggs v. Dunn, defense correctional administration expert Robert Ayers, after visiting six facilities, agreed with plaintiffs' experts that ADOC facilities are understaffed and overcrowded, and explained that mainly due to severe understaffing and lack of documentation he had reason to doubt that correctional officers and mental-health staff were actually complying with ADOC policies. Date: 2017-01-01 Tags: staffing,mental_health,policy,legal Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) - [confirmed] Hale evidence of substantial risk: two years overcrowding and regular fights In Hale v. Tallapoosa County, the evidence the court found sufficient to show a substantial risk of serious harm included that overcrowding had existed at the jail for about two years, fights occurred between inmates on a regular basis during overcrowding, and the violence was severe enough to require medical attention and hospitalization on occasion. Date: 1995-05-02 Tags: violence,conditions,legal Sources: Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener) - [confirmed] Fulton County Jail fails to protect from violence The Fulton County Jail findings include that the Jail does not adequately protect incarcerated people from the substantial risk of serious harm from violence. Date: 2024-11-14 Tags: violence,conditions,legal Sources: Fulton County Jail Investigation Findings - [reported] DOJ summary judgment motion describes pervasive Alabama prison violence The DOJ's summary judgment motion in United States v. Alabama states that Alabama's prisons are pervasively violent, with homicides, stabbings, beatings, and sexual assaults occurring routinely, that officers use excessive force, and that Alabama does not maintain the physical condition of the prisons, putting prisoners' health and safety at risk. Tags: violence,conditions,legal Sources: Federal government seeks summary judgment against Alabama Department of Corrections | Alabama Reflector - [confirmed] First Special Monitor report (November 1979) found extensive non-compliance The First Report of the Special Monitor in Guthrie v. Evans, filed in November 1979, detailed extensive non-compliance by GDC in almost all areas of the consent decrees. Date: 1979-11-01 Tags: legal,conditions,investigations Sources: Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener) - [confirmed] ADOC authorized officer positions based on 1:6 or 1:7 ratio vs. 'ideal' 1:5 In Braggs v. Dunn, ADOC chief of staff Steve Brown testified that ADOC's number of authorized correctional-officer positions was determined based on a staffing ratio of 1:6 or 1:7, which ADOC considered close enough to the 'ideal' ratio of one correctional officer for every five inmates. Tags: staffing,policy,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Purcell: no expert testimony that five-officer staffing was insufficient In Purcell v. Toombs County, the court noted that no expert testified the jail, given its inmate capacity, was understaffed, and nothing in the record demonstrated that the actual staffing level of five officers was insufficient to handle competently situations that would be reasonably anticipated. Date: 2005-02-24 Tags: staffing,legal Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] Braggs v. Dunn: correctional officer shortage hinders mental-health care delivery In Braggs v. Dunn, the court found that in addition to mental-health understaffing and overcrowding, a significant shortage of correctional officers also hinders the delivery of mental-health care. Tags: staffing,mental_health,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Braggs v. Dunn: witnesses including defendants called officer shortage a top obstacle to mental-health care In Braggs v. Dunn, the court found that witness after witness, including both defendants, testified that a significant shortage of correctional officers has been one of the biggest obstacles to providing mental-health care in ADOC. Tags: staffing,mental_health,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] Chandler v. Crosby: district court temperature findings The district court in Chandler v. Crosby found that temperatures on the death-row housing unit were rarely over ninety degrees and never exceeded 100 degrees during the relevant summer readings, and that the ventilation system was operating within design parameters. Tags: conditions,legal Sources: Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004) - [confirmed] Prior panel: 25+ years of 'hopelessly confused' mens rea case law The Wade v. McDade en banc opinion recounts the prior panel's observation that for more than 25 years the Eleventh Circuit's case law on the deliberate-indifference mens rea element had been 'hopelessly confused,' flip-flopping between 'more than mere negligence' and 'more than gross negligence.' Date: 2024-07-10 Tags: legal Sources: Betty Wade v. Georgia Correctional Health, LLC, U.S. Court of Appeals, 11th Circuit, 2024-07-10 (court record via CourtListener) - [confirmed] Purcell: insufficient evidence of constant threat of violence at Toombs County Jail In Purcell v. Toombs County, the Eleventh Circuit held it saw insufficient evidence in the record to show that inmates in the Toombs County Jail were exposed to something even approaching the constant threat of violence. Date: 2005-02-24 Tags: legal,violence Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [reported] Dickinson v. Cochran: DOJ found Mobile County Metro Jail deficiencies exacerbated by lack of policies, training, staffing In Dickinson v. Cochran, the Eleventh Circuit recounted a Department of Justice investigation finding that the security, supervision, and protection from harm deficiencies at the Mobile County Metro Jail were exacerbated by a lack of adequate policies, procedures, training, and staffing, and that such failures significantly increased the risk of violence, placing both inmates and staff at risk of serious harm. Date: 2020-10-28 Tags: staffing,violence,investigations,conditions Sources: Joshua Dickinson v. Sam Cochran, U.S. Court of Appeals, 11th Circuit, 2020-10-28 (court record via CourtListener) - [confirmed] Purcell: jail not understaffed on night of attack; five officers typical In Purcell v. Toombs County, the Eleventh Circuit noted that the jail was not understaffed on the night of the attack, since five officers were on duty, which was typical for Toombs County. Date: 2005-02-24 Tags: staffing,legal Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [reported] Dickinson v. Cochran: DOJ recommended adequate corrections officer staffing and supervision In Dickinson v. Cochran, the Eleventh Circuit noted that the Department of Justice recommended the jail provide adequate corrections officer staffing and supervision to ensure inmate safety. Date: 2020-10-28 Tags: staffing,violence,investigations Sources: Joshua Dickinson v. Sam Cochran, U.S. Court of Appeals, 11th Circuit, 2020-10-28 (court record via CourtListener) - [reported] Jordan v. Doe: FDOC inspection cited cell illumination and plumbing violations In Jordan v. Doe, a Florida Department of Corrections inspection report on the Hillsborough County jail listed as a citable violation that cell illumination was not at least 30 foot candles at 30 inches above the floor, along with plumbing fixtures not meeting the required number per cell or prisoner ratio and not being clean or operational. Date: 1994-12-02 Tags: conditions,facilities Sources: Jordan v. Doe, U.S. Court of Appeals, 11th Circuit, 1994-12-02 (court record via CourtListener) - [confirmed] Purcell summary of Hale evidence: no segregation, one jailer, regular fights In Hale v. Tallapoosa County, as summarized by the Eleventh Circuit in Purcell v. Toombs County, a plaintiff survived summary judgment by submitting evidence that prisoners were not segregated based on their proclivity for violence, there was only one jailer on duty, the jailer's quarters were out of earshot and eyesight of the prisoners' cell, and fights occurred between inmates on a regular basis resulting in injuries requiring medical attention and hospitalization. Date: 2005-02-24 Tags: legal,violence,staffing Sources: Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener) - [confirmed] DOJ finding: low staffing lets violence and criminal activity proliferate DOJ found that with security staffing at such low levels, violence and criminal activity proliferate in GDC prisons, and that GDC fails to stop and respond appropriately to homicides, life-threatening and other serious violence, and sexual abuse, including of vulnerable LGBTI people. Date: 2024-10-01 Tags: violence,staffing,investigations,conditions Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) STATISTICS (16) ---------------------------------------- - [reported] Alabama prison homicide rate 56 per 100,000 in FY2017 DOJ found Alabama's men's prisons had the highest homicide rate in the country, with ADOC reporting nine homicides in fiscal year 2017 in prisons housing about 16,000 prisoners, a rate of 56 per 100,000 prisoners, approximately eight times the 2014 national rate of seven homicides per 100,000 prisoners. Value: 56.0 homicides per 100,000 prisoners (vs. 7 2014 national average homicide rate per 100,000 prisoners) Tags: violence,death,investigations Sources: U.S. Department of Justice, dl - [confirmed] Pack Unit summer indoor temperatures reach 100 degrees In Bailey v. Collier, the Fifth Circuit affirmed class certification where during summer months indoor temperatures within the Pack Unit housing area could reach 100 degrees and consistently exceed 90 degrees. Value: 100.0 degrees Fahrenheit (vs. 90 degrees Fahrenheit consistently exceeded) Date: 2017-08-18 Tags: conditions,facilities,legal Sources: Yates v. Collier, 868 F.3d 354 (5th Cir. 2017) - [reported] 33 weapon assaults facility-wide at Holman, 2005 to Aug 6 2008 In Harrison v. Culliver, the record showed that from 2005 to August 6, 2008, a total of 33 assaults involving weapons were reported facility-wide at Holman, of which only four occurred on the back hallway where the plaintiff was attacked. Value: 33.0 assaults involving weapons (vs. 4 assaults on the back hallway) Tags: violence,facilities,legal Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [reported] DOJ filing cites ADOC staffing ratio of 17.4 prisoners per officer vs. authorized 5.2 In a summary judgment filing in United States v. Alabama, the federal government cited ADOC staffing numbers including a ratio of 17.4 prisoners per correctional officer, versus an authorized ratio of 5.2 prisoners per correctional officer. Value: 17.4 prisoners per correctional officer (vs. 5.2 authorized ratio (prisoners per correctional officer)) Tags: staffing,legal,investigations Sources: DOJ seeks summary judgment finding Alabama failed to protect prisoners - [reported] Alabama prisons employed 1,072 of 3,326 authorized correctional officers According to ADOC's staffing report from June 2018, Alabama's prisons employed only 1,072 out of 3,326 authorized correctional officers. Three prisons had fewer than 20% of authorized correctional officers: Easterling at 17%, Bibb at 19%, and Holman at 19%. Value: 1072.0 correctional officers (vs. 3326 authorized correctional officers) Tags: staffing,facilities Sources: U.S. Department of Justice, dl - [confirmed] Texas prison cells mostly nine by five feet in Ruiz v. Estelle In Ruiz v. Estelle, the Texas prison system's roughly 10,000 cells mostly measured nine feet by five feet, with some as large as sixty-six square feet; most dormitories housed large numbers of inmates and were crowded. Value: 10000.0 cells Date: 1982-06-23 Tags: conditions,facilities,legal Sources: David R. Ruiz, United States of America, Intervenor-Appellee v. W. J. Estelle, Jr., U.S. Court of Appeals, 5th Circuit, 1982-06-23 (court record via CourtListener) - [reported] Holman housed 830-990 inmates during relevant period In Harrison v. Culliver, the District Court's undisputed finding was that Holman housed between 830 and 990 inmates during the relevant time period. Value: 830.0 inmates (low end of range) (vs. 990 inmates (high end of range)) Tags: facilities,demographics Sources: Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener) - [reported] 78 prisoner-on-prisoner homicides in Alabama men's prisons, 2019-2024 A summary judgment filing in United States v. Alabama lists 78 prisoner-on-prisoner homicides from 2019 to 2024 that occurred in men's prisons across the state, including at Bibb, Bullock, Donaldson, Easterling, Elmore, Fountain, Holman, Kilby, Limestone, St. Clair, Staton and Ventress facilities. Value: 78.0 homicides Tags: violence,death,legal,investigations Sources: DOJ seeks summary judgment finding Alabama failed to protect prisoners - [reported] Four Hays State Prison prisoners killed over five weeks (2012-2013) In late 2012 and early 2013, four Hays State Prison prisoners were killed over a five-week period, according to reporting cited in a settlement article. Value: 4.0 deaths (vs. 5 weeks) Tags: violence,death,facilities Sources: $350,000 Settlement for Estate of Prisoner Murdered at Georgia Prison - [confirmed] ADOC filled only 51.1% of authorized correctional officer positions as of September 2016 In Braggs v. Dunn, the M.D. Ala. court found that as of September 2016, ADOC reported having filled only about half of the authorized positions for correctional officers, showing a 51.1% overall staffing level in ADOC's September 2016 Monthly Statistical Report. Value: 51.1 percent of authorized correctional officer positions filled Date: 2016-09-01 Tags: staffing,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [confirmed] ADOC 2015 report: officer shortage over 25% at 13 of 15 major prisons, over 50% at six In Braggs v. Dunn, the court found that ADOC's 2015 annual report showed officer shortage rates of over 25% at 13 of the 15 major Alabama prisons and over 50% at six of those, with the highest shortage rate at 68% at Bibb. Value: 68.0 percent officer shortage at Bibb (highest) (vs. 25 percent shortage threshold exceeded at 13 of 15 major prisons) Date: 2015-01-01 Tags: staffing,facilities,legal Sources: Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302 - [reported] California prison medical and mental health staff vacancy rates at trial At the time of trial, vacancy rates for medical and mental health staff in California's prisons ranged as high as 20% for surgeons, 25% for physicians, 39% for nurse practitioners, and 54.1% for psychiatrists. Value: 54.1 percent vacancy rate for psychiatrists Tags: staffing,medical,mental_health Sources: Brown v. Plata, 09 1233.ZO - [confirmed] 142 GDC prison homicides 2018-2023; 95.8% increase in latter three years DOJ found that over the six-year period from 2018 through 2023, GDC reported a total of 142 homicides in its prisons, with 48 in the first three years and 94 in the latter three years, a 95.8% increase; DOJ stated this rate significantly exceeds the most recent available national data on homicide rates in correctional facilities. Value: 142.0 homicides (vs. 95.8 percent increase in latter three years) Tags: violence,death,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [confirmed] GDC average correctional officer vacancy rates 2021-2023 DOJ found GDC's average correctional officer vacancy rate was 49.3% in 2021, 56.3% in 2022, and 52.5% in 2023. Value: 52.5 percent vacancy rate (2023) (vs. 49.3 percent vacancy rate (2021)) Tags: staffing,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [confirmed] Over 2,800 unfilled CO positions; systemwide vacancy above 50% at end of 2023 DOJ's findings report states that by the end of 2023 GDC still had over 2,800 unfilled correctional officer positions and the systemwide correctional officer vacancy rate remained above 50%. Value: 2800.0 unfilled correctional officer positions (vs. 50 percent systemwide vacancy rate (above)) Date: 2023-01-01 Tags: staffing,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) - [confirmed] 18 GDC prisons over 60% CO vacancy in December 2023; 10 over 70% DOJ found that in December 2023, 18 GDC prisons had correctional officer vacancy rates over 60%, and 10 of those were over 70%. Value: 18.0 prisons over 60% vacancy (vs. 10 prisons over 70% vacancy) Date: 2023-12-01 Tags: staffing,facilities,investigations Sources: DOJ Findings Report: Investigation of Georgia Prisons (October 2024) METHODOLOGY NOTES (1) ---------------------------------------- - [confirmed] Braggs v. Dunn: Dr. Burns interviewed 77 prisoners plus 25 at cell-front across nine facilities In Braggs v. Dunn, plaintiffs' expert Dr. Kathryn Burns visited nine major ADOC facilities, held formal interviews with 77 prisoners and spoke to an additional 25 at cell-front, and identified insufficient mental-health and correctional staffing among a range of problems, opining that these inadequacies subject mentally ill prisoners to a substantial risk of harm. Date: 2017-01-01 Tags: mental_health,staffing,legal Sources: Braggs v. Dunn, 2017-06-27 (court record via CourtListener) DATA GAPS (1) ---------------------------------------- - [confirmed] Data gap: document contains no Georgia-specific prison-conditions statistics The document consists solely of federal appellate citations on Eighth Amendment standards and PLRA procedure; it contains no GDC population, staffing, overdose, death, or facility-level data for Georgia prisons. Any Georgia-specific quantitative claims would require separate sourcing. Tags: legal,conditions Sources: Jerry Nelson v. Keyvon Sellers, Court of Appeals for the Eleventh Circuit, 2024-01-05 (court record via CourtListener) QUOTES (1) ---------------------------------------- - [reported] Jordan v. Doe: dissent describes 24-hour lights and televisions In Jordan v. Doe, Judge Clark's dissent described conditions at the Hillsborough County jail as including rooms where lights burn and televisions blare 24 hours a day. Date: 1994-12-02 Tags: conditions,facilities Sources: Jordan v. Doe, U.S. Court of Appeals, 11th Circuit, 1994-12-02 (court record via CourtListener) DATASETS (2) ---------------------------------------- # Weapon assaults at Holman Correctional Facility, 2005 to August 6, 2008 Facility-wide count of reported assaults involving weapons at Holman, with the subset occurring on the back hallway where the plaintiff in Harrison v. Culliver was attacked. Location Assaults involving weapons -------------------------------------------- Whole facility 33 Back hallway 4 # GDC average correctional officer vacancy rate, 2021-2023 GDC's average correctional officer vacancy rate by year as reported in DOJ's October 2024 findings report. Year Average CO vacancy rate ------------------------------- 2021 49.3 2022 56.3 2023 52.5 KEY ENTITIES (197) ---------------------------------------- - 18 U.S.C. § 3626 [legislation]: Federal statute governing prisoner release orders, consent decrees, and related relief in prison-conditions litigation. (aka: Prison Litigation Reform Act § 3626, 42 U.S.C. § 1997e) - 42 U.S.C. § 1983 [legislation]: Federal civil rights statute providing a cause of action for deprivation of constitutional rights under color of state law. (aka: Civil Rights Act of 1871, Section 1983) - 42 U.S.C. § 1997a [legislation]: Federal statute authorizing the Attorney General to sue over egregious or flagrant conditions in institutions. (aka: Section 1997a) - 42 U.S.C. § 1997b [legislation]: Federal statute setting pre-suit certification and notice requirements for § 1997a actions. (aka: Section 1997b) - 42 U.S.C. § 1997c [legislation]: Federal statute governing intervention by the Attorney General in institutional conditions cases. (aka: Section 1997c) - 42 U.S.C. § 1997e [legislation]: Federal statute requiring exhaustion of administrative remedies and imposing filing-fee and attorney's-fee limits in prisoner litigation. (aka: § 1997e) - Alabama Department of Corrections [organization]: Alabama state corrections agency spending approximately $19.3 million on prison education (~$742/inmate/year) while under federal oversight for unconstitutional conditions - Anderson v. Nosser [case]: Former Fifth Circuit decision (1971) on conditions at Parchman's maximum security unit for Natchez civil-rights demonstrators. - Anderson v. State [case]: New Mexico Supreme Court (2022) case explaining Chandler v. Crosby certification requirement. - Angola [facility]: Louisiana's largest prison, 18,000 acres of farmland. Subject of Ball v. LeBlanc. Camp C continues to operate with no AC and roughly double design capacity as of 2025. (aka: Louisiana State Penitentiary, LSP) - Anthony Alaimo [person]: Judge who presided over the December 2, 1974 hearing in Guthrie v. MacDougall. (aka: Judge Anthony Alaimo) - Arizona Department of Corrections [organization]: Arizona state correctional agency that implemented an STG program beginning in 1991, producing the most rigorously evaluated gang separation case study (aka: ADCR, ADC) - Arkansas Department of Correction [organization]: State prison system involved in Hutto v. Finney. - Ayotte v. Barnhart [case]: District of Maine (2013) case distinguishing Hale v. Tallapoosa County on inmate-on-inmate violence. - Bailey v. Collier [case]: Fifth Circuit appeal (2017) affirming class certification and recognizing Eighth Amendment right against extremely dangerous prison temperatures; involved Texas Pack Unit. (aka: David Bailey v. Bryan Collier) - Baldwin State Prison [facility]: Georgia state prison where 26 grams of methamphetamine were found on a visitor in November 2025. - Baltas v. Chapdelaine [case]: Second Circuit decision (2025-09-03) applying Hutto v. Finney to overcrowded cell and 'grue' diet conditions. - Bell Atlantic Corp. v. Twombly [case]: 2007 Supreme Court pleading-standard decision that abrogated Marsh v. Butler County on other grounds. (aka: Twombly) - Benning v. Commissioner, Georgia Department of Corrections [case]: Eleventh Circuit case (2023) citing 18 U.S.C. § 3626(a)(1)(A); followed Thomas v. Bryant. (aka: Ralph Harrison Benning v. Commissioner, Georgia Department of Corrections) - Benning v. Oliver [case]: Pro se federal civil-rights litigation regarding First Amendment correspondence claims in M.D. Ga.; certiorari denied April 29, 2024; referenced as one of multiple cases documenting GDC credibility issues (aka: 5:18-cv-00087) - Bibb Correctional Facility [facility]: Alabama prison with the highest officer shortage rate (68%) in ADOC's 2015 annual report. (aka: Bibb) - Bobby K. Whitworth [person]: GDC Commissioner in 1992 who requested a GBI investigation into GWCI staff misconduct allegations. - Bonner v. City of Prichard [case]: En banc Eleventh Circuit decision adopting pre-1981 Fifth Circuit precedent as binding in the Eleventh Circuit. (aka: 661 F.2d 1206 (11th Cir. 1981)) - Bounds v. Smith [case]: 1977 Supreme Court case establishing constitutional right of meaningful access to courts through adequate law libraries or trained legal assistance (aka: Bounds v. Smith, 430 U.S. 817 (1977)) - Bowen Ex Rel. Estate of Bowen v. Warden, Baldwin State Prison [case]: Eleventh Circuit case regarding Eighth Amendment failure-to-protect claims after Terrance Bowen was beaten to death by his cellmate. - Boyd v. Nichols [case]: Federal Middle District of Georgia case involving sexual assault in county jail. Court declined to determine whether Abuse Provision extends beyond federal protections. (aka: Boyd v. Nichols, 616 F. Supp. 2d 1331 (M.D. Ga. 2009)) - Braggs v. Dunn [case]: M.D. Ala. Eighth Amendment class action on mental-health care in Alabama prisons; 2017 liability opinion found Commissioner and Associate Commissioner of Health Services violated the Eighth Amendment. (aka: Case 2:14-cv-00601-MHT-TFM) - Brooks v. Warden [case]: Eleventh Circuit (2015) decision affirming dismissal of a riot failure-to-protect claim but reviving a basic-sanitation claim and denying qualified immunity to the deputy warden. (aka: Fred Dalton Brooks v. Warden) - Brown v. Plata [case]: 2011 Supreme Court case upholding order to reduce California prison population due to overcrowding causing inadequate healthcare - Bryant v. Rich [case]: 2008 Eleventh Circuit case establishing exhaustion as a precondition to adjudication on the merits. (aka: 530 F.3d 1368) - Caldwell v. Warden, FCI Talladega [case]: Eleventh Circuit (2014) decision stating that the substantial-risk-of-serious-harm element is examined under an objective standard. (aka: Trevis Caldwell v. Warden, FCI Talladega) - California Department of Corrections and Rehabilitation [organization]: California state agency responsible for operating the state prison system; defendant in Brown v. Plata litigation (aka: CDCR, California prisons) - Carl Hoffer v. Secretary, Florida Department of Corrections [case]: Eleventh Circuit (2020) case explaining Thomas v. Bryant's particularized-findings requirement. (aka: Hoffer v. Florida DOC) - Cason v. Seckinger [case]: Georgia prison-conditions class action filed in 1984 over Middle Georgia Correctional Complex; resolved by fourteen consent decrees (1990-1996); partial termination vacated and remanded by the Eleventh Circuit in 2000. (aka: Buddy Cason v. Jim Seckinger) - Chandler v. Baird [case]: Eleventh Circuit case establishing a well-established Eighth Amendment right not to be confined in conditions lacking basic sanitation. - Chandler v. Crosby [case]: Eleventh Circuit decision holding that the Eighth Amendment applies to inadequate cooling and ventilation but that mere discomfort does not offend it; controlling heat precedent for Georgia federal courts. (aka: 379 F.3d 1278 (11th Cir. 2004)) - Chapman v. Dunn [case]: Eleventh Circuit 2025 decision involving Georgia Department of Corrections Commissioner Jefferson Dunn, applying Wade v. McDade. (aka: Michael Chapman v. Jefferson Dunn) - Civil Rights of Institutionalized Persons Act [legislation]: Federal statute authorizing DOJ to investigate and sue state/local governments for pattern or practice of constitutional violations in prisons, jails, juvenile facilities, mental health facilities, nursing homes, and disability institutions (aka: CRIPA, 42 U.S.C. § 1997) - Clayton County Sheriff's Office [organization]: Georgia county sheriff's office involved in Goodman v. Kimbrough. (aka: Clayton County Sheriff Kemuel Kimbrough) - Coleman v. Brown [case]: Federal class action filed 1990 challenging failure to diagnose and treat mental illness in California prisons; ongoing for 35 years; led to 2025 receivership (aka: Coleman v. Wilson, Coleman v. Wilson, 912 F. Supp. 1282 (E.D. Cal. 1995)) - CRIPA [legislation]: Federal statute (1980) authorizing the Attorney General to investigate pattern-or-practice constitutional violations in publicly operated facilities (aka: Civil Rights of Institutionalized Persons Act, Civil Rights of Institutionalized Persons Act of 1980) - Daughtry v. Emmons [case]: Class action challenging solitary confinement conditions in GDCP Special Management Unit. Filed 2015 pro se by Timothy Gumm; December 2018 settlement; April 2024 contempt order with $2,500/day fines. (aka: Gumm v. Jacobs, Gumm v. Jacobs / Daughtry v. Emmons, Case No. 5:15-cv-00041-MTT-CHW) - Davis v. Commonwealth [case]: Massachusetts Appeals Court (2019) case following Turner v. Burnside on unavailable remedies. - DeKalb County Jail [facility]: County jail at issue in Hamm v. DeKalb County, where overcrowding, food service, and medical care claims were rejected. - Dewalt v. Hooks [case]: Supreme Court of North Carolina (2022) case following Braggs v. Dunn. - Dickinson v. Cochran [case]: Eleventh Circuit decision (2020) recounting DOJ findings on security, supervision, and staffing deficiencies at the Mobile County Metro Jail. - Dimanche v. Brown [case]: Eleventh Circuit case holding that threats of retaliation can render the formal grievance process unavailable under Ross v. Blake - Dockery v. Cain [case]: Fifth Circuit (2021) case affirming denial of injunction after five-week bench trial on EMCF conditions. (aka: Dockery v. Hall) - Dockery v. Fischer [case]: 2015 case describing proposed EMCF class and three subclasses. - DOJ Civil Rights Division [organization]: Federal agency that conducted the investigation of Georgia prisons resulting in the October 2024 findings report (aka: U.S. Department of Justice, DOJ) - Donald Freed v. Michelle Thomas [case]: Sixth Circuit decision (2025-05-12) applying Hutto v. Finney to States' Eleventh Amendment immunity. (aka: Freed v. Thomas) - Dunn v. Dunn [case]: Alabama prisoner mental-health litigation addressing vicarious exhaustion for Rule 23(b)(2) classes. (aka: Braggs v. Dunn) - East Mississippi Correctional Facility [facility]: Mississippi private prison subject of Dockery class action over Eighth Amendment conditions. (aka: EMCF) - Easterling Correctional Facility [facility]: Alabama prison whose heating, cooling and ventilation conditions were at issue in Ivory v. Warden. - Eldon Vail [person]: Plaintiffs' correctional administration expert in Braggs v. Dunn who testified ADOC understaffing was 'shocking.' - Eleventh Circuit [organization]: Federal appellate court with jurisdiction over Georgia, Florida and Alabama; author of Chandler v. Crosby. (aka: U.S. Court of Appeals for the Eleventh Circuit) - Eleventh Circuit Court of Appeals [organization]: Federal appeals court controlling litigation from Georgia, Florida, and Alabama; adopted 'ordinary firmness' test for retaliation claims (aka: Eleventh Circuit) - Estelle v. Gamble [case]: 1976 U.S. Supreme Court decision establishing that deliberate indifference by prison personnel to a prisoner's serious illness or injury constitutes cruel and unusual punishment under the Eighth Amendment. - Fambro v. Fulton County [case]: N.D. Ga. decision (1989) finding Fulton County jail in continuous violation of a five-year consent decree. - Farmer v. Brennan [case]: U.S. Supreme Court case establishing the deliberate indifference two-part test (objective + subjective components) for Eighth Amendment prison conditions claims. The bedrock case for all prisoner rights litigation. (aka: 511 U.S. 825 (1994)) - Federal Rule of Civil Procedure 23 [legislation]: Federal rule governing class-action certification requirements. (aka: Rule 23) - Fifth Circuit [organization]: Federal appellate court with jurisdiction over Texas, Mississippi and Louisiana; author of the Gates, Ball, Hinojosa, Yates and Coones heat decisions. (aka: U.S. Court of Appeals for the Fifth Circuit) - Florida Department of Corrections [organization]: Florida state corrections agency referenced in analysis of contractor profit margins from penny-per-meal savings in a 90,000-prisoner system. - Foster v. Fulton County [case]: Class action by HIV-positive Fulton County Jail inmates; final order 2000 required improved medical care. (aka: 1:99-cv-00900) - Fourth Circuit [organization]: Federal appellate court cited for Hope v. Pelzer and Hutto v. Finney applications. (aka: U.S. Court of Appeals for the Fourth Circuit, 4th Cir.) - Fulton County Jail [facility]: Facility subject to a new 2025 DOJ consent decree addressing unconstitutional conditions. - Fulton County Sheriff's Office [organization]: Party to the proposed DOJ consent decree over Fulton County Jail conditions. - Gates v. Collier [case]: Fifth Circuit decision (501 F.2d 1291, 1319 (5th Cir. 1974)) cited for the principle that financial considerations do not excuse noncompliance with a remedial order. - Genesis HealthCare Corp. v. Symczyk [case]: Supreme Court (2013) case discussing Sosna v. Iowa and Geraghty relation-back doctrine for class actions. - Georgia Advisory Committee to the U.S. Commission on Civil Rights [organization]: Committee that conducted the investigation and hearings documented in this 1976 report. (aka: Georgia Advisory Committee, Advisory Committee) - Georgia Advocacy Office v. Theodore Jackson [case]: Eleventh Circuit case (2021) construing PLRA § 3626(a)(1)(A) prospective-relief requirements. - Georgia Department of Corrections [organization]: State agency responsible for operating Georgia's prison system. Subject of federal DOJ investigation in 2022-2023 for constitutional violations including food-related deaths. (aka: GDC) - Georgia Diagnostic and Classification Prison [facility]: Georgia state prison from which David 'Toro' Zavala operated drug trafficking while serving time for armed robbery. - Georgia Legal Services [organization]: Legal services organization that filed Cason v. Seckinger and reported GWCI staff misconduct allegations in 1992. - Georgia State Board of Pardons and Paroles [organization]: Georgia state agency responsible for parole decisions - Georgia State Prison at Reidsville [facility]: Georgia state prison opened in 1937, subject of Guthrie v. Evans consent decree. Closed by GDC in 2022. Heat-retentive concrete construction documented in Guthrie record. (aka: Georgia State Prison, Reidsville) - Georgia Women's Correctional Institution [facility]: The only state institution reserved strictly for women offenders. Served as initial processing facility for female inmates. (aka: GWCI, Georgia Women's Correctional Institute) - Gillette v. Prosper [case]: District Court of the Virgin Islands decision (2016) reciting the PLRA definition of 'prisoner release order.' - Gilmore v. Georgia Department of Corrections [case]: En banc Eleventh Circuit decision (2025) discussing Taylor v. Riojas and the obvious-clarity standard for Eighth Amendment claims. (aka: Clarissa Gilmore v. Georgia Department of Corrections) - Glades Correctional Institution [facility]: Florida prison whose dormitory air conditioning and ventilation were at issue in Green v. Secretary. - Gomes v. U.S. Department of Homeland Security [case]: District of New Hampshire (2020) case distinguishing Money v. Pritzker. (aka: Robson Xavier Gomes v. US Department of Homeland Security) - Goodman v. Kimbrough [case]: Eleventh Circuit decision whose 'more than gross negligence' element was abrogated by Wade v. McDade. - Grochowski v. Clayton County [case]: Eleventh Circuit case (2020) on Fourteenth Amendment Due Process claims, following Hamm v. DeKalb County. - Gumm v. Jacobs [case]: Federal class action lawsuit challenging conditions in Georgia's Special Management Unit. Filed pro se by Timothy Gumm in 2015. Settlement reached January 2019. 100-page contempt order issued April 2024 finding GDC 'flagrantly violated' the settlement. Filed in U.S. District Court, Middle District of Georgia. - Guthrie v. Evans [case]: Class action lawsuit filed in 1972 challenging racial segregation and unconstitutional conditions at Georgia State Prison, resulting in the most comprehensive set of remedial decrees ever imposed on a single U.S. prison facility. Presided over by Judge Anthony A. Alaimo for thirteen years. (aka: Guthrie v. MacDougall, Guthrie v. Caldwell, Guthrie v. Ault, Guthrie v. Evans, Civ. No. 3068, Civil Action No. 3068) - Guthrie v. MacDougall [case]: Court case whose order resulted in new grievance procedures included in the 1975 inmate handbook. - Hale v. Tallapoosa County [case]: Eleventh Circuit case addressing knowingly tolerated objectively intolerable conditions of confinement. - Hamm v. DeKalb County [case]: Eleventh Circuit precedent followed by Grochowski v. Clayton County. - Harper v. Bennett [case]: Conditions-of-confinement lawsuit against Fulton County and GDC; consent order 2005 set staffing and population limits. (aka: 1:04-cv-01416) - Harris v. Thigpen [case]: Case establishing that medical care need not be 'perfect, the best obtainable, or even very good' to meet Eighth Amendment requirements - Harrison v. Culliver [case]: Eleventh Circuit (2014) case characterizing risk as 'constant threat of violence' and rejecting Eighth Amendment claim involving box cutter attack. - Hayes Williams v. Edwin Edwards [case]: Fifth Circuit (1977) case affirming findings that Angola prison conditions shocked the conscience. (aka: Williams v. Edwards) - Hays State Prison [facility]: Georgia state prison visited by DOJ during 2022-2023 investigation (aka: Hays) - Helling v. McKinney [case]: Supreme Court case holding that exposure to future harm (environmental tobacco smoke) can violate the Eighth Amendment (aka: 509 U.S. 25 (1993)) - Henderson v. Thomas [case]: M.D. Ala. case (2012) holding that the fluid nature of a prison plaintiff class favors certification of all present and future members. - Hinojosa v. Livingston [case]: Fifth Circuit decision in a Texas heat-stroke death case affirming limited discovery before ruling on qualified immunity. (aka: 807 F.3d 657 (5th Cir. 2015)) - Hoffer v. Jones [case]: Case certifying a class of Florida prisoners with chronic hepatitis C virus. - Holman Correctional Facility [facility]: Alabama prison with 19% of authorized correctional officer staffing as of June 2018. - Holmes v. Continental Can Co. [case]: Eleventh Circuit decision discussing the homogeneity requirement for Rule 23(b)(2) classes. (aka: Gloria Holmes v. Continental Can Company) - Hope v. Pelzer [case]: U.S. Supreme Court case, 536 U.S. 730 (2002), arising from Alabama. Held that handcuffing a prisoner to a hitching post for seven hours in the sun constituted obvious cruel and unusual punishment. Directly analogous to Georgia heat exposure cases. - Hudson v. McMillian [case]: Supreme Court case distinguishing excessive force claims from conditions-of-confinement claims. - Hutto v. Finney [case]: Supreme Court decision upholding a 30-day limit on isolation sentences as part of a remedy for unconstitutional prison conditions. (aka: October Term, 1977) - Jefferson Dunn [person]: Alabama prison Commissioner who testified in Braggs v. Dunn about the 'two-headed monster' of overcrowding and understaffing. (aka: Commissioner Dunn) - Jerry Nelson v. Keyvon Sellers [case]: Eleventh Circuit decision (2024-01-05) distinguishing Goodman v. Kimbrough on deliberate-indifference standards. (aka: Nelson v. Sellers) - Jonathan R. v. Patrick Morrisey [case]: Fourth Circuit decision (2026-06-04) explaining Hutto v. Finney's affirmance of precise relief orders. (aka: Jonathan R. v. Morrisey) - Jones v. Bock [case]: 2007 Supreme Court case holding that prison requirements define the boundaries of proper exhaustion. (aka: 549 U.S. 199) - Jordan v. Doe [case]: Eleventh Circuit case (1994) involving conditions at the Hillsborough County jail, including overcrowding, 24-hour lighting, and inspection violations. - Kathryn Burns [person]: Plaintiffs' mental-health expert in Braggs v. Dunn who visited nine ADOC facilities and interviewed 77 prisoners plus 25 at cell-front. (aka: Dr. Kathryn Burns) - Kingsley v. Hendrickson [case]: Supreme Court case establishing objective unreasonableness standard for pretrial detainee excessive force claims under the Fourteenth Amendment, creating circuit split on extension to conditions claims (aka: 576 U.S. 389 (2015)) - Lacy v. Coughlin [case]: Massachusetts Appeals Court (2021) case discussing Harrison v. Culliver and substantial-risk-of-harm standard. (aka: ANTONIO LACY v. JOHN COUGHLIN & another.) - Lake Correctional Institution [facility]: Georgia state prison referenced in Stalley v. Lake CI Warden. (aka: Lake CI) - LaMarca v. Turner [case]: Eleventh Circuit case finding an unconstitutional risk of violence due to weapons, lack of patrols, and lack of officer supervision. - Lane v. Philbin [case]: Case applying the totality rule originating in Gates v. Collier. - Laube v. Haley [case]: District court decision (2002) with fact findings on Birmingham segregation 'holding cell' conditions. - Lewis v. Casey [case]: 1996 Supreme Court case narrowing Bounds by requiring 'actual injury' to challenge prison legal access, creating a Catch-22 for inmates (aka: Lewis v. Casey, 518 U.S. 343 (1996)) - M.D. v. Perry [case]: Fifth Circuit decision (2012) applying Wal-Mart's commonality standard to a proposed class. (aka: M.D. Ex Rel. Stukenberg v. Perry) - Marbury v. Warden [case]: 11th Circuit case (936 F.3d 1227, 2019) holding that deliberate indifference may include evidence of pervasive staffing and logistical issues rendering prison officials unable to address near-constant violence. - Marbury v. Warden III [case]: Eleventh Circuit decision (2026) addressing pleading standards and noting Marsh v. Butler County was abrogated on other grounds by Twombly. - Mark Charlton-Perkins v. Univ. of Cincinnati [case]: Sixth Circuit decision (2026-08-05) applying Hope v. Pelzer to bathroom-break denial and confinement conditions. (aka: Charlton-Perkins v. Univ. of Cincinnati) - Marsh v. Butler County [case]: Eleventh Circuit case finding staffing and security failures posed a substantial risk of serious harm. - McKinnon v. Talladega County [case]: Eleventh Circuit decision (1984) holding prisoner transfer or release moots individual injunctive claims and can justify dismissal of uncertified class actions. - Metro West Detention Center [facility]: Miami-Dade County detention facility at issue in Swain v. Junior. - Miami-Dade County Jail [facility]: Jail involved in Swain v. Junior COVID-19 litigation. (aka: Miami jail) - Middle Georgia Correctional Complex [facility]: Georgia correctional complex that was the subject of the Cason v. Seckinger class action. - Miles-El v. State of Michigan [case]: Sixth Circuit (2026) case distinguishing Helling v. McKinney. (aka: Kushawn Miles-El v. State of Michigan) - Miller v. French [case]: Supreme Court case holding that the PLRA's automatic stay provision is mandatory and does not violate separation of powers. (aka: Miller, Superintendent, Pendleton Correctional Facility v. French, 530 U.S. 327) - Missouri Department of Corrections [organization]: Missouri state prison agency, defendant in Postawko. (aka: MDOC) - Mobile County Metro Jail [facility]: Alabama jail subject to DOJ investigation finding security, supervision, and protection-from-harm deficiencies exacerbated by lack of policies, training, and staffing. - Money v. Pritzker [case]: N.D. Ill. case (No. 20-CV-2093) distinguished in Gomes. - Mosley v. Zachery [case]: Eleventh Circuit case where officer who responded reasonably to known threat (sending inmate to monitored cell) was found not liable despite inmate being later attacked - Newman v. Alabama [case]: Former Fifth Circuit decision (1977) affirming a remedial decree requiring adequate food, clothing, shelter, sanitation, medical attention and personal safety in Alabama prisons. - Office of the Public Guardian v. Elliot Hospital [case]: District of New Hampshire (2022) case following Braggs v. Dunn on untreated serious medical risk. (aka: Office of the Public Guardian v. P Elliot Hospital, et al.) - Oqueshia Andrews v. Carmel Biggers, Jr. [case]: Eleventh Circuit decision (2021-05-07) following Purcell v. Toombs County on Eleventh Amendment immunity. (aka: Andrews v. Biggers) - Pack Unit [facility]: Texas prison housing unit where summer indoor temperatures reach 100 degrees and consistently exceed 90 degrees, per Bailey v. Collier. - Parsons v. Ryan [case]: Ninth Circuit case affirming certification of statewide class challenging Arizona prison medical, dental, mental health, and isolation policies. (aka: Victor Parsons v. Charles Ryan) - Paul H. Roney [person]: Chief Judge who authored the Eleventh Circuit's 1987 opinion in Guthrie v. Evans. - Pena v. Starr County, Texas [case]: Fifth Circuit case (2026) citing Farmer v. Brennan on obvious risk. - Pendleton Correctional Facility [facility]: Indiana prison named in the case caption of Miller v. French. - Peralta v. Dillard [case]: Ninth Circuit en banc decision (2014) explaining LaMarca v. Turner on personal liability and official-capacity injunctive relief. (aka: Cion Peralta v. T. Dillard) - Perttu v. Richards [case]: Supreme Court case (2025) holding that when PLRA exhaustion dispute involves same facts as merits, jury (not judge) must decide if intertwined with Seventh Amendment jury trial right - Plata v. Newsom [case]: California prison overcrowding litigation; order cites 18 U.S.C. § 3626(a)(3)(B) on three-judge courts for prisoner release orders. (aka: Coleman/Plata three-judge court) - PLRA [legislation]: Federal statute governing prisoner release orders, requiring a three-judge panel and specific findings before population reduction can be ordered. (aka: Prison Litigation Reform Act, 18 U.S.C. § 3626) - Postawko v. Missouri Department of Corrections [case]: Eighth Circuit (2018) case affirming certification of class of HCV inmates denied direct-acting antiviral treatment. (aka: Michael Postawko v. Missouri Dept of Corrections) - Prison Litigation Reform Act [legislation]: 1996 federal legislation that imposed filing fees, administrative exhaustion requirements, attorney fee limits, and a 'three strikes' rule on prisoner civil rights litigation. Caused a 33% drop in federal civil rights filings by prisoners between 1995-1997. (aka: PLRA) - Pugh v. Locke [case]: M.D. Ala. district court decision (1976) prescribing remedies for cruel and unusual punishment in Alabama prisons, affirmed with modifications in Newman v. Alabama. - Purcell v. Toombs County [case]: Eleventh Circuit precedent followed by Boyd v. Nichols. - Raymond Alwyn McMahon v. Malcolm Beard [case]: Fifth Circuit (1978) case distinguishing solitary-cell conditions from unsanitary-cell precedent. (aka: McMahon v. Beard) - Reidsville State Prison [facility]: Georgia prison that remained segregated until July 1974 despite a federal court order requiring integration by January 1969. (aka: Reidsville) - Reiyn Keohane v. Florida Department of Corrections Secretary [case]: Eleventh Circuit (2020) case explaining Thomas v. Bryant's 'reimagining' of its holding. (aka: Keohane v. Florida DOC) - Rhodes v. Chapman [case]: Supreme Court case holding that double-celling is not per se unconstitutional under the Eighth Amendment (aka: 452 U.S. 337 (1981)) - Ricardo McClinton v. Warden, Baldwin State Prison [case]: Eleventh Circuit decision (2026-04-14) applying Marbury v. Warden and Goodman v. Kimbrough in a Georgia prisoner deliberate-indifference case. (aka: McClinton v. Warden) - Richardson v. Johnson [case]: Eleventh Circuit decision (2010) restating the objective and subjective components of Eighth Amendment conditions claims. - Robert Ayers [person]: Defense correctional administration expert in Braggs v. Dunn who agreed ADOC facilities are understaffed and overcrowded. - Ross v. Blake [case]: 578 U.S. ___ (2016) — Supreme Court case identifying three circumstances where PLRA exhaustion is excused due to unavailability of remedies - Ruiz v. Estelle [case]: Fifth Circuit case (1982) describing Texas prison cell sizes and dormitory crowding. (aka: David R. Ruiz v. W. J. Estelle, Jr.) - Second Circuit [organization]: Federal appellate court cited for Hutto v. Finney application to overcrowded cell conditions. (aka: U.S. Court of Appeals for the Second Circuit, 2d Cir.) - Sixth Circuit [organization]: Federal appellate court cited for Hope v. Pelzer and Hutto v. Finney applications. (aka: U.S. Court of Appeals for the Sixth Circuit, 6th Cir.) - SOP 227.02 [legislation]: GDC Standard Operating Procedure effective 5/10/2019 that expressly prohibits retaliation against offenders for filing grievances. (aka: Statewide Grievance Procedure) - Sosna v. Iowa [case]: Supreme Court case holding class actions not moot after named plaintiff's claim moot post-certification. - Southern Center for Human Rights [organization]: Legal advocacy organization that investigated food conditions at Gordon County Jail and sent a formal letter to Sheriff Mitch Ralston in October 2014. (aka: SCHR) - Southern Ohio Correctional Facility [facility]: Ohio prison at issue in Rhodes v. Chapman, which housed 38% more inmates than its design capacity. (aka: SOCF) - Spain v. Procunier [case]: Ninth Circuit decision cited in Wilson v. Seiter for outdoor exercise requirements where prisoners are confined almost 24 hours in small cells. - Stalley v. Lake CI Warden [case]: Eleventh Circuit 2024 decision involving a Georgia state prison (Lake Correctional Institution) warden, applying Wade v. McDade. (aka: Douglas Stalley v. Lake CI Warden) - State of Utah v. Su [case]: Fifth Circuit case (2024) discussing Miller v. French on prospective relief. - Steve Brown [person]: ADOC chief of staff who testified in Braggs v. Dunn about the 1:6 or 1:7 staffing ratio used to set authorized officer positions. - Supreme Court of the United States [organization]: Highest federal court, which decided Hutto v. Finney and Miller v. French. (aka: Supreme Court) - Swain v. Junior [case]: Eleventh Circuit decision vacating a COVID-19 preliminary injunction against a Miami jail for failure to show subjective recklessness. (aka: Anthony Swain v. Daniel Junior) - Tallapoosa County Jail [facility]: Jail at issue in Hale v. Tallapoosa County, where overcrowding and regular inmate violence supported an Eighth Amendment claim. - Taylor v. Riojas [case]: Supreme Court case establishing that some conduct is so obviously unconstitutional that no prior case is needed to overcome qualified immunity; involved prisoner held in feces-covered cells for 6 days (aka: 141 S. Ct. 52 (2020)) - Texas Department of Criminal Justice [organization]: Texas corrections agency; former executive director testified as expert witness that overcrowding is 'primary cause' of violations (aka: TDCJ) - Thomas v. Bryant [case]: Eleventh Circuit precedent followed by Benning v. Commissioner, GDC. - Thorpe v. Weaver [case]: Fifth Circuit decision (2026-07-08) explaining that Hope v. Pelzer's obviousness exception does not relieve plaintiffs of their burden. - Toombs County Jail [facility]: Georgia jail at issue in Purcell v. Toombs County; housed over a hundred inmates and had five officers on duty on the night of the attack. - Tracey Edwards v. Benita Witherspoon [case]: Fourth Circuit decision (2026-09-10) applying Hope v. Pelzer to novel factual circumstances. (aka: Edwards v. Witherspoon) - Turner v. Burnside [case]: 2008 Eleventh Circuit case establishing that threats of retaliation can make administrative remedies unavailable. (aka: 541 F.3d 1077) - Tutwiler Prison for Women [facility]: Alabama women's prison excluded from the Braggs v. Dunn Phase 2A class. (aka: Tutwiler) - Tyrone Oliver [person]: Commissioner of the Georgia Department of Corrections who in March 2024 stopped including preliminary cause of death in monthly mortality reports. (aka: Commissioner Oliver, GDC Commissioner) - U.S. Court of Appeals for the Eleventh Circuit [organization]: Federal appellate court that decided United States v. Davis and Newsome. (aka: 11th Circuit) - U.S. Department of Justice [organization]: Federal agency that published October 2024 findings report on unconstitutional conditions in Georgia prisons. (aka: DOJ) - U.S. Parole Comm'n v. Geraghty [case]: Supreme Court case establishing relation-back doctrine for erroneous denial of class certification. (aka: Geraghty) - United States v. Alabama [case]: DOJ Eighth Amendment prison-conditions lawsuit against Alabama; DOJ filed a summary judgment motion ahead of a scheduled November trial. - United States v. State of Alabama [case]: DOJ prison-conditions litigation against Alabama and the Alabama Department of Corrections; DOJ filed a summary judgment motion on September 2, 2026. (aka: Civil No. 2:20-cv-01971-HDM) - United States v. State of Florida [case]: Eleventh Circuit (2026) case applying Lewis v. Casey's systemwide-relief standard. - Valentine v. Collier [case]: Fifth Circuit decision (2020) staying a COVID-19 injunction and articulating PLRA narrow-tailoring and public-safety/comity requirements for preliminary relief. (aka: Laddy Valentine v. Bryan Collier) - Wade v. Daniels [case]: Eleventh Circuit 2022 decision applying Swain v. Junior. (aka: Nicholas C. Wade v. Solomon Daniels) - Wade v. McDade [case]: En banc Eleventh Circuit decision (July 2024) that fundamentally redefined deliberate indifference, requiring plaintiff to prove official was subjectively aware that his OWN conduct put plaintiff at substantial risk. Makes Georgia Eighth Amendment claims significantly harder. (aka: 106 F.4th 1251 (11th Cir. 2024)) - Wal-Mart Stores, Inc. v. Dukes [case]: Supreme Court case establishing commonality requirement for class certification. (aka: Dukes) - Walker v. Schult [case]: Second Circuit decision (2013) citing Chandler v. Crosby. - Wallace Pack Unit [facility]: TDCJ minimum-security facility in Navasota, Texas, holding approximately 1,300 men. Subject of Cole v. Collier litigation. First Texas prison to receive court-ordered permanent AC. (aka: Pack Unit) - Ware State Prison [facility]: Georgia state prison leading all GDC facilities in cell phone seizures by end of 2016, with 1,392 phones confiscated. - Wells v. Warden [case]: 2023 Eleventh Circuit en banc case holding a failure-to-exhaust dismissal is not automatically a PLRA strike. (aka: 58 F.4th 1347) - Whatley v. Warden [case]: Eleventh Circuit decision (2015) involving a Georgia prisoner's 'imminent danger' grievance about being beaten and transferred without treatment. (aka: Shawn Wayne Whatley v. Warden, Ware State Prison) - Whitley v. Albers [case]: Supreme Court decision cited for the culpable-state-of-mind requirement and identified as the wrong standard applied by the Sixth Circuit in Wilson v. Seiter. - Wilson v. Seiter [case]: 1991 Supreme Court case extending deliberate indifference standard to conditions of confinement and establishing Section 1983 liability for administrators - Woodford v. Ngo [case]: 548 U.S. 81 (2006) — Supreme Court case mandating 'proper exhaustion' with strict compliance under PLRA - Yates v. Collier [case]: Fifth Circuit decision affirming class certification for the Wallace Pack Unit heat case. (aka: 868 F.3d 354 (5th Cir. 2017)) - Zell Miller [person]: Former Georgia Governor who in 1995 instituted the administrative regulation banning financial aid for incarcerated students, driven by reelection anxiety. (aka: Governor Zell Miller) SOURCES (205) ---------------------------------------- - § 1997a TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5244, U.S. Government Publishing Office (2024-01-01) [legal_document, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2024-title42/pdf/USCODE-2024-title42-chap21-subchapI-A-sec1997a.pdf - § 1997d TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5212, U.S. Government Publishing Office (2023-01-01) [legislation, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2023-title42/pdf/USCODE-2023-title42-chap21-subchapI-A-sec1997e.pdf - § 1997f TITLE 42—THE PUBLIC HEALTH AND WELFARE Page 5248, U.S. Government Publishing Office (2024-01-01) [legislation, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2024-title42/pdf/USCODE-2024-title42-chap21-subchapI-A-sec1997j.pdf - § 3626 Title 18—CRIMES and Criminal Procedure Page 848, U.S. Government Publishing Office (2023-01-01) [legislation, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2023-title18/pdf/USCODE-2023-title18-partII-chap229-subchapC-sec3626.pdf - $350,000 Settlement for Estate of Prisoner Murdered at Georgia Prison, Prison Legal News (2016-02-02) [journalism, secondary] URL: https://www.prisonlegalnews.org/news/2016/feb/2/350000-settlement-estate-prisoner-murdered-georgia-prison/ - 18 USC 3626: Appropriate remedies with respect to prison conditions, U.S. House of Representatives, Office of the Law Revision Counsel [legislation, primary] URL: https://web.archive.org/web/20250325003932id_/http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title18-section3626&num=0&edition=prelim - 1992 annual report, Georgia Department of Corrections / Digital Library of Georgia (1992-01-01) [official_report, primary] URL: https://dlg.galileo.usg.edu/id:dlg_ggpd_y-ga-br300-b-pa1-b1992 - 1994 annual report, Georgia Department of Corrections (1994-01-01) [official_report, primary] URL: https://dlg.galileo.usg.edu/id:dlg_ggpd_y-ga-br300-b-pa1-b1994 - 31 Fair empl.prac.cas. 1707, 32 Empl. Prac. Dec. P 33,668 Gloria Holmes v. Continental Can Company, U.S. Court of Appeals, 11th Circuit, 1983-06-09 (court record via CourtListener), CourtListener (1983-06-09) [legal_document, primary] URL: https://www.courtlistener.com/opinion/418095/31-fair-emplpraccas-1707-32-empl-prac-dec-p-33668-gloria-holmes-v/ - 338 October Term, 2010, Library of Congress (2010-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep564/usrep564338/usrep564338.pdf - 995 F.2d 1526 (1993), Clearinghouse (1993-01-01) [legal_document, primary] URL: https://clearinghouse-umich-production.s3.amazonaws.com/media/doc/56471.pdf - Anderson v. Hutson, Court of Appeals for the Fifth Circuit, 2024-08-26 (court record via CourtListener), CourtListener (2024-08-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10074782/anderson-v-hutson/ - Anderson v. State, New Mexico Supreme Court, 2022-08-25 (court record via CourtListener), CourtListener (2022-08-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10701694/anderson-v-state/ - Anthony Swain v. Daniel Junior, U.S. Court of Appeals, 11th Circuit, 2020-06-15 (court record via CourtListener), CourtListener (2020-06-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4761029/anthony-swain-v-daniel-junior/ - ANTONIO LACY v. JOHN COUGHLIN & another., Massachusetts Appeals Court, 2021-10-06 (court record via CourtListener), CourtListener (2021-10-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10271978/antonio-lacy-v-john-coughlin-another/ - Aura Lopez-Lopez v. Todd Blanche, Court of Appeals for the Eighth Circuit, 2026-07-07 (court record via CourtListener), CourtListener (2026-07-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10917119/aura-lopez-lopez-v-todd-blanche/ - Ayotte v. Barnhart, District Court, D. Maine, 2013-09-24 (court record via CourtListener), CourtListener (2013-09-24) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8728494/ayotte-v-barnhart/ - Baltas v. Chapdelaine, Court of Appeals for the Second Circuit, 2025-09-03 (court record via CourtListener), CourtListener (2025-09-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10665311/baltas-v-chapdelaine/ - Benjamin Carter v. Beth Cabell, Court of Appeals for the Fourth Circuit, 2026-08-04 (court record via CourtListener), CourtListener (2026-08-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10940319/benjamin-carter-v-beth-cabell/ - Betty Wade v. Georgia Correctional Health, LLC, U.S. Court of Appeals, 11th Circuit, 2024-07-10 (court record via CourtListener), CourtListener (2024-07-10) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9999275/betty-wade-v-georgia-correctional-health-llc/ - Bowen Ex Rel. Estate of Bowen v. Warden, Baldwin State Prison, U.S. Court of Appeals, 11th Circuit, 2016-06-22 (court record via CourtListener), U.S. Court of Appeals for the Eleventh Circuit (2016-06-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/3216028/bowen-ex-rel-estate-of-bowen-v-warden-baldwin-state-prison/ - Boyd v. Nichols, District Court, M.D. Georgia, 2009-05-05 (court record via CourtListener), CourtListener (2009-05-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/1811716/boyd-v-nichols/ - Braggs v. Dunn, 2017-06-27 (court record via CourtListener), CourtListener (2017-06-27) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7325978/braggs-v-dunn/ - Braggs v. Dunn, 2019-05-04 (court record via CourtListener), CourtListener (2019-05-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7336214/braggs-v-dunn/ - Brent Jacoby v. Baldwin County, Court of Appeals for the Eleventh Circuit, 2016-08-29 (court record via CourtListener), CourtListener (2016-08-29) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4252176/brent-jacoby-v-baldwin-county/ - Brown v. Plata, 09 1233.ZO, Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/supct/html/09-1233.ZO.html - Brown v. Plata, 09 1233.ZS, Cornell Legal Information Institute (2011-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supct/html/09-1233.ZS.html - Bryant v. Rich, U.S. Court of Appeals, 11th Circuit, 2008-06-20 (court record via CourtListener), CourtListener (2008-06-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/78047/bryant-v-rich/ - Buddy Cason v. Jim Seckinger, U.S. Court of Appeals, 11th Circuit, 2000-10-24 (court record via CourtListener), CourtListener (2000-10-24) [legal_document, primary] URL: https://www.courtlistener.com/opinion/74903/buddy-cason-v-jim-seckinger/ - Carl Hoffer v. Secretary, Florida Department Corrections, Court of Appeals for the Eleventh Circuit, 2020-08-31 (court record via CourtListener), CourtListener (2020-08-31) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4781315/carl-hoffer-v-secretary-florida-department-corrections/ - Case 2:14-cv-00601-MHT-JTA Document 3461 Filed 12/27/21 Page 1 of 49, SPLC (2021-12-27) [legal_document, primary] URL: https://www.splcenter.org/wp-content/uploads/2021/12/phase_2a_omnibus_remedial_opinion_part_i.pdf - Case 2:14-cv-00601-MHT-TFM Document 1285 Filed 06/27/17 Page 1 of 302, Southern Poverty Law Center (2017-06-27) [legal_document, primary] URL: https://www.splcenter.org/wp-content/uploads/files/documents/the_opinion.pdf - Case 2:20-cv-01971-HDM Document 378 Filed 09/02/26 Page 1 of 260 FILED, U.S. District Court, N.D. Alabama (via Alabama Reflector) by United States of America (2026-09-02) [legal_document, primary] URL: https://alabamareflector.com/wp-content/uploads/2026/09/DOJMSJ.pdf - Case: 1:20-cv-02093 Document #: 38 Filed: 04/10/20 Page 1 of 48 PageID #:587, UPLC Chicago (2020-04-10) [legal_document, primary] URL: https://www.uplcchicago.org/file_download/4f136264-82ee-4d85-b16e-5f46c4f5c537 - Cases Adjudged (tile.loc.gov), Library of Congress [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep503/usrep503001/usrep503001.pdf - Cason v. Seckinger 5:84-cv-00313 (M.D. Ga.) | Civil Rights Litigation Clearinghouse, Civil Rights Litigation Clearinghouse [legal_document, secondary] URL: https://clearinghouse.net/case/650/ - Chandler v. Baird, U.S. Court of Appeals, 11th Circuit, 1991-03-15 (court record via CourtListener), CourtListener (1991-03-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/556561/chandler-v-baird/ - Chandler v. Crosby, 379 F.3d 1278 (11th Cir. 2004), U.S. Court of Appeals for the Eleventh Circuit (2004-08-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/76715/jim-e-chandler-v-james-crosby/ - Chandler v. Crosby, U.S. Court of Appeals, 11th Circuit, 2004-08-06 (court record via CourtListener), CourtListener (2004-08-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/76715/chandler-v-crosby/ - Christopher Varner v. Stan Shepard, Court of Appeals for the Eleventh Circuit, 2021-08-31 (court record via CourtListener), CourtListener (2021-08-31) [legal_document, primary] URL: https://www.courtlistener.com/opinion/5064892/christopher-varner-v-stan-shepard/ - Cion Peralta v. T. Dillard, Court of Appeals for the Ninth Circuit, 2014-03-06 (court record via CourtListener), CourtListener (2014-03-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2655912/cion-peralta-v-t-dillard/ - Cite as: 592 U. S. ____ (2020) 1, Supreme Court of the United States (2020-01-01) [legal_document, primary] URL: https://www.supremecourt.gov/opinions/20pdf/19-1261_g3bh.pdf - Civil Rights Division | Georgia Juvenile Facilities Memorandum Agreement, U.S. Department of Justice [official_report, primary] URL: https://www.justice.gov/crt/georgia-juvenile-facilities-memorandum-agreement - Civil Rights Division | Special Litigation Section Cases and Matters, U.S. Department of Justice [official_report, primary] URL: https://www.justice.gov/crt/about/spl/findsettle.php - Civil Rights Litigation Clearinghouse, Gumm v. Jacobs case profile, Civil Rights Litigation Clearinghouse [data_portal, secondary] URL: https://clearinghouse.net/case/15981/ - Civil Rights Litigation Clearinghouse, Guthrie v. Evans case page, Civil Rights Litigation Clearinghouse, University of Michigan Law School [data_portal, primary] URL: https://clearinghouse.net/case/655/ - Clarissa Gilmore v. Georgia Department of Corrections, U.S. Court of Appeals, 11th Circuit, 2025-07-11 (court record via CourtListener), CourtListener (2025-07-11) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10631717/clarissa-gilmore-v-georgia-department-of-corrections/ - Coleman v. Brown, District Court, E.D. California, 2013-06-20 (court record via CourtListener), CourtListener (2013-06-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8726277/coleman-v-brown/ - Conrad L. Hoever v. R. Marks, Court of Appeals for the Eleventh Circuit, 2021-04-09 (court record via CourtListener), CourtListener (2021-04-09) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4872413/conrad-l-hoever-v-r-marks/ - Court record, M.D. Ga., 2026-02-10 (court record via CourtListener), CourtListener (2026-02-10) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10841821/ralph-harrison-benning-v-commr-tyrone-oliver-et-al/ - Court record, U.S. Court of Appeals, 5th Circuit, 1977-11-07 (court record via CourtListener), CourtListener (1977-11-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/347581/n-h-newman-v-state-of-alabama-jerry-lee-pugh-for-himself-and-others/ - Danyale Tubbs v. Sherry Payton, Court of Appeals for the Sixth Circuit, 2026-09-10 (court record via CourtListener), CourtListener (2026-09-10) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10970585/danyale-tubbs-v-sherry-payton/ - David R. Ruiz, United States of America, Intervenor-Appellee v. W. J. Estelle, Jr., U.S. Court of Appeals, 5th Circuit, 1982-06-23 (court record via CourtListener), CourtListener (1982-06-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/404985/david-r-ruiz-united-states-of-america-intervenor-appellee-v-w-j/ - Davis v. Commonwealth, Massachusetts Appeals Court, 2019-06-03 (court record via CourtListener), CourtListener (2019-06-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7179119/davis-v-commonwealth/ - Dewalt v. Hooks, Supreme Court of North Carolina, 2022-11-04 (court record via CourtListener), CourtListener (2022-11-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9352557/dewalt-v-hooks/ - Dockery v. Cain, U.S. Court of Appeals, 5th Circuit, 2021-08-05 (court record via CourtListener), CourtListener (2021-08-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4905661/dockery-v-cain/ - Dockery v. Fischer, 2015-09-29 (court record via CourtListener), CourtListener (2015-09-29) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7325651/dockery-v-fischer/ - DOJ Findings Report: Investigation of Georgia Prisons (October 2024), U.S. Department of Justice (2024-10-01) [official_report, primary] URL: https://www.justice.gov/d9/2024-09/findings_report_-_investigation_of_georgia_prisons.pdf - DOJ Investigation of Georgia Prisons, Civil Rights Litigation Clearinghouse, Civil Rights Litigation Clearinghouse [data_portal, secondary] URL: https://clearinghouse.net/case/18216/ - DOJ Press Release: Justice Department Announces Investigation into Conditions in Georgia Prisons, U.S. Department of Justice (2024-01-01) [press_release, primary] URL: https://www.justice.gov/archives/opa/pr/justice-department-announces-investigation-conditions-georgia-prisons - DOJ seeks summary judgment finding Alabama failed to protect prisoners, WSFA (2026-09-03) [journalism, secondary] URL: https://www.wsfa.com/2026/09/03/doj-seeks-summary-judgement-finding-alabama-failed-protect-prisoners/ - Donald Freed v. Michelle Thomas, Court of Appeals for the Sixth Circuit, 2025-05-12 (court record via CourtListener), CourtListener (2025-05-12) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10582254/donald-freed-v-michelle-thomas/ - Donald Grochowski v. Clayton County, Georgia, Court of Appeals for the Eleventh Circuit, 2020-06-22 (court record via CourtListener), CourtListener (2020-06-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4762720/donald-grochowski-v-clayton-county-georgia/ - Douglas Stalley v. Lake CI Warden, Court of Appeals for the Eleventh Circuit, 2024-12-30 (court record via CourtListener), CourtListener (2024-12-30) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10305655/douglas-stalley-v-lake-ci-warden/ - Dunn v. Dunn, 2016-09-09 (court record via CourtListener), CourtListener (2016-09-09) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8792310/dunn-v-dunn/ - Dunn v. Dunn, 2016-11-25 (court record via CourtListener), CourtListener (2016-11-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7322826/dunn-v-dunn/ - Edward Braggs v. Commissioner, Alabama Department of Corrections, Court of Appeals for the Eleventh Circuit, 2026-06-24 (court record via CourtListener), CourtListener (2026-06-24) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10879722/edward-braggs-v-commissioner-alabama-department-of-corrections/ - Eric Moss v. Buddy Harwood, Court of Appeals for the Fourth Circuit, 2021-12-02 (court record via CourtListener), CourtListener (2021-12-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/5302589/eric-moss-v-buddy-harwood/ - Fambro v. Fulton County, Ga., N.D. Ga., 1989-04-21 (court record via CourtListener), CourtListener (1989-04-21) [legal_document, primary] URL: https://www.courtlistener.com/opinion/1465483/fambro-v-fulton-county-ga/ - Faour Fraihat v. US Imm. & Customs Enforcement, Court of Appeals for the Ninth Circuit, 2021-10-20 (court record via CourtListener), CourtListener (2021-10-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/5296746/faour-fraihat-v-us-imm-customs-enforcement/ - Farmer v. Brennan, 511 U.S. 825 (1994)., Cornell Legal Information Institute (1994-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supct/html/92-7247.ZO.html - Federal government seeks summary judgment against Alabama Department of Corrections | Alabama Reflector, Alabama Reflector (2026-09-03) [journalism, secondary] URL: https://web.archive.org/web/20260907091857id_/https://alabamareflector.com/2026/09/03/federal-government-seeks-summary-judgment-against-alabama-department-of-corrections/ - Foster v. Fulton County 1:99-cv-00900 (N.D. Ga.) | Civil Rights Litigation Clearinghouse, Civil Rights Litigation Clearinghouse [academic, secondary] URL: https://clearinghouse.net/case/75/ - Fred Dalton Brooks v. Warden, U.S. Court of Appeals, 11th Circuit, 2015-09-03 (court record via CourtListener), CourtListener (2015-09-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2844883/fred-dalton-brooks-v-warden/ - Fulton County Jail Investigation Findings, U.S. Department of Justice (2024-11-14) [official_report, primary] URL: https://www.justice.gov/crt/media/1377016/dl - Fulton County Jail Reform, U.S. Department of Justice (2025-01-01) [official_report, primary] URL: https://www.justice.gov/crt/media/1384111/dl - Genesis HealthCare Corp. v. Symczyk, Supreme Court of the United States, 2013-04-16 (court record via CourtListener), CourtListener (2013-04-16) [legal_document, primary] URL: https://www.courtlistener.com/opinion/858086/genesis-healthcare-corp-v-symczyk/ - George Hamm v. Dekalb County, and Pat Jarvis, Sheriff, U.S. Court of Appeals, 11th Circuit, 1985-11-04 (court record via CourtListener), CourtListener (1985-11-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/459883/george-hamm-v-dekalb-county-and-pat-jarvis-sheriff/ - Georgia Advocacy Office v. Theodore Jackson, U.S. Court of Appeals, 11th Circuit, 2021-07-14 (court record via CourtListener), CourtListener (2021-07-14) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4899739/georgia-advocacy-office-v-theodore-jackson/ - Georgia Prisons, National Criminal Justice Reference Service [official_report, primary] URL: https://www.ncjrs.gov/pdffiles1/Digitization/69997NCJRS.pdf - Georgia Prisons Investigation Findings, U.S. Department of Justice, Civil Rights Division [official_report, primary] URL: https://www.justice.gov/crt/media/1371456/dl - GEORGIA STATE BOARD OF PARDONS AND PAROLES: ANNUAL REPORT, JULY 1, 1992-JUNE 30, 1993, Georgia State Board of Pardons and Paroles (1993-01-01) [official_report, primary] URL: https://www.ncjrs.gov/pdffiles1/Digitization/148288NCJRS.pdf - Gillette v. Prosper, District Court, Virgin Islands, 2016-03-04 (court record via CourtListener), CourtListener (2016-03-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8211978/gillette-v-prosper/ - Gonzalez v. Commissioner of Correction, Connecticut Appellate Court, 2022-04-05 (court record via CourtListener), CourtListener (2022-04-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/6457342/gonzalez-v-commissioner-of-correction/ - Guthrie v. Evans, S.D. Ga., 1981-12-31 (court record via CourtListener), CourtListener (1981-12-31) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8813887/guthrie-v-evans/ - Hale v. Tallapoosa County, U.S. Court of Appeals, 11th Circuit, 1995-05-02 (court record via CourtListener), CourtListener (1995-05-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7032035/hale-v-tallapoosa-county/ - Hamm v. Ochsner-Acadia, Court of Appeals for the Fifth Circuit, 2026-08-19 (court record via CourtListener), CourtListener (2026-08-19) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10953721/hamm-v-ochsner-acadia/ - Harper v. Bennet, 2004-06-25 (court record via CourtListener), CourtListener (2004-06-25) [legal_document, primary] URL: https://www.courtlistener.com/docket/4243276/ - Harper v. Bennett 1:04-cv-01416 (N.D. Ga.) | Civil Rights Litigation Clearinghouse, Civil Rights Litigation Clearinghouse [academic, secondary] URL: https://clearinghouse.net/case/5509/ - Hayes Williams v. Edwin Edwards, Governor of the State of Louisiana, Defendants, U.S. Court of Appeals, 5th Circuit, 1977-03-15 (court record via CourtListener), CourtListener (1977-03-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/342252/hayes-williams-v-edwin-edwards-governor-of-the-state-of-louisiana/ - Helling v. McKinney, 509 U.S. 25 (1993)., Cornell Legal Information Institute (1993-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supct/html/91-1958.ZO.html - Hewitt v. United States, Supreme Court of the United States, 2025-06-26 (court record via CourtListener), CourtListener (2025-06-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10776823/hewitt-v-united-states/ - Hinojosa v. Livingston, 807 F.3d 657 (5th Cir. 2015), U.S. Court of Appeals for the Fifth Circuit (2015-11-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/3155936/ramona-hinojosa-v-brad-livingston/ - Hoffer v. Jones, 2017-11-17 (court record via CourtListener), CourtListener (2017-11-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7328488/hoffer-v-jones/ - In Re: Blue Cross Blue Shield Antitrust Litigation, Court of Appeals for the Eleventh Circuit, 2023-10-25 (court record via CourtListener), CourtListener (2023-10-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9435183/in-re-blue-cross-blue-shield-antitrust-litigation/ - Jamaal Ali Bilal v. Geo Care, LLC, Court of Appeals for the Eleventh Circuit, 2020-11-23 (court record via CourtListener), CourtListener (2020-11-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4831640/jamaal-ali-bilal-v-geo-care-llc/ - Jeremy John Wells v. Warden, Court of Appeals for the Eleventh Circuit, 2023-02-01 (court record via CourtListener), CourtListener (2023-02-01) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9372330/jeremy-john-wells-v-warden/ - Jerry Nelson v. Keyvon Sellers, Court of Appeals for the Eleventh Circuit, 2024-01-05 (court record via CourtListener), CourtListener (2024-01-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9458042/jerry-nelson-v-keyvon-sellers/ - Jim Eric Chandler v. Captain William Baird, U.S. Court of Appeals, 11th Circuit, 1991-03-15 (court record via CourtListener), CourtListener (1991-03-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/556561/jim-eric-chandler-v-captain-william-baird/ - Jody O'Neil Harrison v. Grantt Culliver, U.S. Court of Appeals, 11th Circuit, 2014-04-02 (court record via CourtListener), CourtListener (2014-04-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2663212/jody-oneil-harrison-v-grantt-culliver/ - Jonathan Michael Burton v. Dr. G. Espino, Court of Appeals for the Eleventh Circuit, 2026-08-25 (court record via CourtListener), CourtListener (2026-08-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10957435/jonathan-michael-burton-v-dr-g-espino/ - Jonathan R. v. Patrick Morrisey, Court of Appeals for the Fourth Circuit, 2026-06-04 (court record via CourtListener), CourtListener (2026-06-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10870949/jonathan-r-v-patrick-morrisey/ - Jones v. Bock, Supreme Court of the United States, 2007-01-22 (court record via CourtListener), CourtListener (2007-01-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/145763/jones-v-bock/ - Jordan v. Doe, U.S. Court of Appeals, 11th Circuit, 1994-12-02 (court record via CourtListener), CourtListener (1994-12-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/7030592/jordan-v-doe/ - Joshua Dickinson v. Sam Cochran, U.S. Court of Appeals, 11th Circuit, 2020-10-28 (court record via CourtListener), CourtListener (2020-10-28) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4801010/joshua-dickinson-v-sam-cochran/ - Justice Department Reaches Proposed Consent Decree with Fulton County, U.S. DOJ, U.S. Department of Justice (2025-02-06) [press_release, primary] URL: https://www.justice.gov/archives/opa/pr/justice-department-reaches-proposed-consent-decree-fulton-county-georgia-and-fulton-county - Katie Ruth Anderson v. J. J. Nosser, James Bradley v. J. J. Nosser, U.S. Court of Appeals, 5th Circuit, 1971-05-27 (court record via CourtListener), CourtListener (1971-05-27) [legal_document, primary] URL: https://www.courtlistener.com/opinion/294828/katie-ruth-anderson-v-j-j-nosser-james-bradley-v-j-j-nosser/ - Keith J. HUDSON, Petitioner, v. Jack McMILLIAN et al. | Supreme Court | US Law | LII / Legal Information Institute, Cornell Legal Information Institute (1992-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supremecourt/text/503/1 - Kevin Smith v. Christopher Price, Court of Appeals for the Seventh Circuit, 2026-08-19 (court record via CourtListener), CourtListener (2026-08-19) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10953780/kevin-smith-v-christopher-price/ - Kingsley v. Hendrickson, Supreme Court of the United States, 2015-06-22 (court record via CourtListener), CourtListener (2015-06-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2811847/kingsley-v-hendrickson/ - Kushawn Miles-El v. State of Michigan, Court of Appeals for the Sixth Circuit, 2026-10-09 (court record via CourtListener), CourtListener (2026-10-09) [legal_document, primary] URL: https://www.courtlistener.com/opinion/11024778/kushawn-miles-el-v-state-of-michigan/ - Laddy Valentine v. Bryan Collier, U.S. Court of Appeals, 5th Circuit, 2020-04-22 (court record via CourtListener), CourtListener (2020-04-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4747567/laddy-valentine-v-bryan-collier/ - Laddy Valentine v. Bryan Collier, U.S. Court of Appeals, 5th Circuit, 2020-10-13 (court record via CourtListener), CourtListener (2020-10-13) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4795752/laddy-valentine-v-bryan-collier/ - LaMarca v. Turner, U.S. Court of Appeals, 11th Circuit, 1993-07-07 (court record via CourtListener), CourtListener (1993-07-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9018561/lamarca-v-turner/ - Laube v. Haley, 2002-12-02 (court record via CourtListener), CourtListener (2002-12-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2513159/laube-v-haley/ - law.cornell.edu: 1253, Cornell Legal Information Institute (2024-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/28/1253 - law.cornell.edu: 1983, Cornell Law School Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/42/1983 - law.cornell.edu: 1997a, Cornell Law School Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/42/1997a - law.cornell.edu: 1997b, Cornell Law School Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/42/1997b - law.cornell.edu: 1997c, Cornell Law School Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/42/1997c - law.cornell.edu: 1997j, Cornell Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/42/1997j - law.cornell.edu: 2284, Cornell Legal Information Institute (2024-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/28/2284 - law.cornell.edu: 343, Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/supremecourt/text/518/343 - law.cornell.edu: 3626, Cornell Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/uscode/text/18/3626 - law.cornell.edu: 730, Cornell Legal Information Institute (2002-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supremecourt/text/536/730 - Lawrence Burns v. Sterling Polk, Court of Appeals for the Seventh Circuit, 2026-08-18 (court record via CourtListener), CourtListener (2026-08-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10953230/lawrence-burns-v-sterling-polk/ - M.D. Ex Rel. Stukenberg v. Perry, U.S. Court of Appeals, 5th Circuit, 2012-03-23 (court record via CourtListener), CourtListener (2012-03-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/626025/md-ex-rel-stukenberg-v-perry/ - Machelle Pearson v. MDOC, Court of Appeals for the Sixth Circuit, 2026-03-26 (court record via CourtListener), CourtListener (2026-03-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10816966/machelle-pearson-v-mdoc/ - Mackie L. Shivers, Jr. v. USA, Court of Appeals for the Eleventh Circuit, 2021-06-09 (court record via CourtListener), CourtListener (2021-06-09) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4890380/mackie-l-shivers-jr-v-usa/ - Marbury v. Warden III, U.S. Court of Appeals, 11th Circuit, 2026-07-07 (court record via CourtListener), CourtListener (2026-07-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10917302/marbury-v-warden-iii/ - Mark Charlton-Perkins v. Univ. of Cincinnati, Court of Appeals for the Sixth Circuit, 2026-08-05 (court record via CourtListener), CourtListener (2026-08-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10940226/mark-charlton-perkins-v-univ-of-cincinnati/ - Marsh v. Butler County, U.S. Court of Appeals, 11th Circuit, 2001-09-26 (court record via CourtListener), CourtListener (2001-09-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/775291/marsh-v-butler-county/ - Mary Goodman v. Clayton County Sheriff Kemuel Kimbrough, U.S. Court of Appeals, 11th Circuit, 2013-06-21 (court record via CourtListener), CourtListener (2013-06-21) [legal_document, primary] URL: https://www.courtlistener.com/opinion/931601/mary-goodman-v-clayton-county-sheriff-kemuel-kimbrough/ - McKinnon v. Talladega County, U.S. Court of Appeals, 11th Circuit, 1984-11-05 (court record via CourtListener), CourtListener (1984-11-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8934987/mckinnon-v-talladega-county/ - media.ca11.uscourts.gov: 200911658, Eleventh Circuit Court of Appeals (2009-01-01) [legal_document, primary] URL: https://media.ca11.uscourts.gov/opinions/pub/files/200911658.pdf - Michael Chapman v. Jefferson Dunn, Court of Appeals for the Eleventh Circuit, 2025-02-25 (court record via CourtListener), CourtListener (2025-02-25) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10339192/michael-chapman-v-jefferson-dunn/ - Michael Postawko v. Missouri Dept of Corrections, U.S. Court of Appeals, 8th Circuit, 2018-12-06 (court record via CourtListener), CourtListener (2018-12-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4570682/michael-postawko-v-missouri-dept-of-corrections/ - Michael Rinaldi v. United States, Court of Appeals for the Third Circuit, 2018-09-12 (court record via CourtListener), CourtListener (2018-09-12) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4534941/michael-rinaldi-v-united-states/ - Miller v. French, Cornell Legal Information Institute (2000-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supct/html/99-224.ZO.html - Miller v. French | 530 U.S. 327 (2000) | Justia U.S. Supreme Court Center, Justia (via Internet Archive) (2000-01-01) [legal_document, primary] URL: https://web.archive.org/web/20260604000421id_/https://supreme.justia.com/cases/federal/us/530/327/ - Miller v. French, Supreme Court of the United States, 2000-06-19 (court record via CourtListener), CourtListener (2000-06-19) [legal_document, primary] URL: https://www.courtlistener.com/opinion/118378/miller-v-french/ - MILLER, SUPERINTENDENT, PENDLETON CORRECTIONAL FACILITY, et al. v. FRENCH, et al. | Supreme Court | US Law | LII / Legal Information Institute, Cornell Legal Information Institute (2000-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/supremecourt/text/530/327 - Mitchell Marbury v. Warden III, Court of Appeals for the Eleventh Circuit, 2026-07-07 (court record via CourtListener), CourtListener (2026-07-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10917302/mitchell-marbury-v-warden-iii/ - Mitchell Marbury v. Warden, U.S. Court of Appeals, 11th Circuit, 2019-08-29 (court record via CourtListener), CourtListener (2019-08-29) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4657195/mitchell-marbury-v-warden/ - Moliere Dimanche, Jr. v. Jerry Brown, U.S. Court of Appeals, 11th Circuit, 2015-04-17 (court record via CourtListener), CourtListener (2015-04-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2794632/moliere-dimanche-jr-v-jerry-brown/ - Nazareth Gates, and United States of America, Plaintiff-Intervenor-Appellee v. John Collier, Superintendent, Mississippi State Penitentiary, Court of Appeals for the Fifth Circuit, 1974-09-20 (court record via CourtListener), CourtListener (1974-09-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/321166/nazareth-gates-and-united-states-of-america-plaintiff-intervenor-appellee/ - Newman v. Alabama, U.S. Court of Appeals, 5th Circuit, 1977-09-16 (court record via CourtListener), CourtListener (1977-09-16) [legal_document, primary] URL: https://www.courtlistener.com/opinion/8914899/newman-v-alabama/ - Nicholas C. Wade v. Solomon Daniels, Court of Appeals for the Eleventh Circuit, 2022-06-13 (court record via CourtListener), CourtListener (2022-06-13) [legal_document, primary] URL: https://www.courtlistener.com/opinion/6477278/nicholas-c-wade-v-solomon-daniels/ - Nuuh Na'im v. James Beck, Court of Appeals for the Eighth Circuit, 2026-04-15 (court record via CourtListener), CourtListener (2026-04-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10843326/nuuh-naim-v-james-beck/ - October Term, 1977, Library of Congress (1978-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep437/usrep437678/usrep437678.pdf - October Term, 1990, Library of Congress (1990-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep501/usrep501294/usrep501294.pdf - October Term, 1992, Library of Congress (1992-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep509/usrep509025/usrep509025.pdf - October Term, 1993, Library of Congress (1994-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep511/usrep511825/usrep511825.pdf - October Term, 2001, Library of Congress, U.S. Reports (536 U.S. 730) (2002-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep536/usrep536730/usrep536730.pdf - Office of the Public Guardian v. P Elliot Hospital, et al., District Court, D. New Hampshire, 2022-09-15 (court record via CourtListener), CourtListener (2022-09-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10695717/office-of-the-public-guardian-v-p-elliot-hospital-et-al/ - Oqueshia Andrews v. Carmel Biggers, Jr., Court of Appeals for the Eleventh Circuit, 2021-05-07 (court record via CourtListener), CourtListener (2021-05-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4881268/oqueshia-andrews-v-carmel-biggers-jr/ - Page 5245 TITLE 42—THE PUBLIC HEALTH AND WELFARE § 1997c, U.S. Government Publishing Office (2024-01-01) [legislation, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2024-title42/pdf/USCODE-2024-title42-chap21-subchapI-A-sec1997c.pdf - Page 835 Title 18—CRIMES and Criminal Procedure § 3626, U.S. Government Publishing Office (2020-01-01) [legislation, primary] URL: https://www.govinfo.gov/content/pkg/USCODE-2020-title18/pdf/USCODE-2020-title18-partII-chap229-subchapC-sec3626.pdf - Pena v. Starr County, Texas, Court of Appeals for the Fifth Circuit, 2026-08-28 (court record via CourtListener), CourtListener (2026-08-28) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10961724/pena-v-starr-county-texas/ - Perttu v. Richards, Supreme Court of the United States, 2025-06-18 (court record via CourtListener), CourtListener (2025-06-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10610021/perttu-v-richards/ - Plata v. Newsom, 2020-04-04 (court record via CourtListener), CourtListener (2020-04-04) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9596997/plata-v-newsom/ - Prison Litigation Reform Act, 42 U.S.C. § 1997e, U.S. Congress (1996-04-26) [legislation, primary] URL: https://www.law.cornell.edu/uscode/text/42/1997e - Purcell Ex Rel. Estate of Morgan v. Toombs County, GA, U.S. Court of Appeals, 11th Circuit, 2005-02-24 (court record via CourtListener), CourtListener (2005-02-24) [legal_document, primary] URL: https://www.courtlistener.com/opinion/76841/purcell-ex-rel-estate-of-morgan-v-toombs-county-ga/ - Ralph Harrison Benning v. Commissioner, Georgia Department of Corrections, Court of Appeals for the Eleventh Circuit, 2023-06-23 (court record via CourtListener), CourtListener (2023-06-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9409050/ralph-harrison-benning-v-commissioner-georgia-department-of-corrections/ - Raymond Alwyn McMahon v. Malcolm Beard, Sheriff of Hillsborough County, Florida, U.S. Court of Appeals, 5th Circuit, 1978-11-02 (court record via CourtListener), CourtListener (1978-11-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/359521/raymond-alwyn-mcmahon-v-malcolm-beard-sheriff-of-hillsborough-county/ - Reiyn Keohane v. Florida Department of Corrections Secretary, Court of Appeals for the Eleventh Circuit, 2020-12-03 (court record via CourtListener), CourtListener (2020-12-03) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4835361/reiyn-keohane-v-florida-department-of-corrections-secretary/ - Rhodes v. Chapman, Library of Congress (1981-01-01) [legal_document, primary] URL: https://tile.loc.gov/storage-services/service/ll/usrep/usrep452/usrep452337/usrep452337.pdf - Rhodes v. Chapman | 452 U.S. 337 (1981) | Justia U.S. Supreme Court Center, Justia (via Internet Archive) (1981-01-01) [legal_document, primary] URL: https://web.archive.org/web/20261011222748id_/https://supreme.justia.com/cases/federal/us/452/337/ - Rhodes v. Chapman, Supreme Court of the United States, 1981-06-15 (court record via CourtListener), CourtListener (1981-06-15) [legal_document, primary] URL: https://www.courtlistener.com/opinion/110518/rhodes-v-chapman/ - Ricardo McClinton v. Warden, Baldwin State Prison, U.S. Court of Appeals, 11th Circuit, 2026-04-14 (court record via CourtListener), CourtListener (2026-04-14) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10842610/ricardo-mcclinton-v-warden-baldwin-state-prison/ - Richardson v. Johnson, Court of Appeals for the Eleventh Circuit, 2010-03-02 (court record via CourtListener), CourtListener (2010-03-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/78596/richardson-v-johnson/ - Robson Xavier Gomes v. US Department of Homeland Security, Acting Secretary et. al., District Court, D. New Hampshire, 2020-05-14 (court record via CourtListener), CourtListener (2020-05-14) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10696950/robson-xavier-gomes-v-us-department-of-homeland-security-acting-secretary/ - Rodney Manyon Lane v. Ted Philbin, Court of Appeals for the Eleventh Circuit, 2016-08-26 (court record via CourtListener), CourtListener (2016-08-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4251589/rodney-manyon-lane-v-ted-philbin/ - Rodney Manyon Lane v. Ted Philbin, U.S. Court of Appeals, 11th Circuit, 2016-08-26 (court record via CourtListener), CourtListener (2016-08-26) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4251537/rodney-manyon-lane-v-ted-philbin/ - Ross v. Blake, Supreme Court of the United States, 2016-06-06 (court record via CourtListener), CourtListener (2016-06-06) [legal_document, primary] URL: https://www.courtlistener.com/opinion/3209793/ross-v-blake/ - Rule 23. Class Actions | Federal Rules of Civil Procedure | US Law | LII / Legal Information Institute, Legal Information Institute, Cornell Law School (2023-01-01) [legal_document, primary] URL: https://www.law.cornell.edu/rules/frcp/rule_23 - S.D. v. Reese, Court of Appeals for the Ninth Circuit, 2026-09-17 (court record via CourtListener), CourtListener (2026-09-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10975732/sd-v-reese/ - Shawn Wayne Whatley v. Warden, Ware State Prison, U.S. Court of Appeals, 11th Circuit, 2015-09-23 (court record via CourtListener), CourtListener (2015-09-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2993506/shawn-wayne-whatley-v-warden-ware-state-prison/ - SOP 227.02 (IIB05-0001), Statewide Grievance Procedure, Georgia Department of Corrections, effective May 10, 2019, Georgia Department of Corrections by Georgia Department of Corrections (2019-05-10) [official_report, primary] URL: https://public.powerdms.com/GADOC/documents/105711 - Special Litigation Section Case Summaries, U.S. Department of Justice Civil Rights Division [official_report, primary] URL: https://www.justice.gov/crt/special-litigation-section-case-summaries - State of Utah v. Su, Court of Appeals for the Fifth Circuit, 2024-07-18 (court record via CourtListener), CourtListener (2024-07-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10007091/state-of-utah-v-su/ - Taylor v. Riojas, Supreme Court of the United States, 2020-11-02 (court record via CourtListener), CourtListener (2020-11-02) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4802501/taylor-v-riojas/ - Terrell Don HUTTO et al., Petitioners, v. Robert FINNEY et al. | Supreme Court | US Law | LII / Legal Information Institute, Legal Information Institute [legal_document, primary] URL: https://www.law.cornell.edu/supremecourt/text/437/678 - Terrence Hammock v. Gail Watts, Court of Appeals for the Fourth Circuit, 2025-07-23 (court record via CourtListener), CourtListener (2025-07-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10640557/terrence-hammock-v-gail-watts/ - Theodore Bolick v. Joel Anderson, Court of Appeals for the Fourth Circuit, 2026-03-13 (court record via CourtListener), CourtListener (2026-03-13) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10808870/theodore-bolick-v-joel-anderson/ - Thomas v. Bryant, U.S. Court of Appeals, 11th Circuit, 2010-08-20 (court record via CourtListener), CourtListener (2010-08-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/173758/thomas-v-bryant/ - Thorpe v. Weaver, Court of Appeals for the Fifth Circuit, 2026-07-08 (court record via CourtListener), CourtListener (2026-07-08) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10921340/thorpe-v-weaver/ - Tiffany Wingo v. Major Branson Harris, Court of Appeals for the Eleventh Circuit, 2025-12-01 (court record via CourtListener), CourtListener (2025-12-01) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10745291/tiffany-wingo-v-major-branson-harris/ - Tommy L. Mosley, Jr. v. Lt. Towanda Zachery, U.S. Court of Appeals, 11th Circuit, 2020-07-24 (court record via CourtListener), CourtListener (2020-07-24) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4770691/tommy-l-mosley-jr-v-lt-towanda-zachery/ - Tracey Edwards v. Benita Witherspoon, Court of Appeals for the Fourth Circuit, 2026-09-10 (court record via CourtListener), CourtListener (2026-09-10) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10972090/tracey-edwards-v-benita-witherspoon/ - Trevis Caldwell v. Warden, FCI Talladega, U.S. Court of Appeals, 11th Circuit, 2014-04-07 (court record via CourtListener), CourtListener (2014-04-07) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2669059/trevis-caldwell-v-warden-fci-talladega/ - Turner v. Burnside, U.S. Court of Appeals, 11th Circuit, 2008-08-28 (court record via CourtListener), CourtListener (2008-08-28) [legal_document, primary] URL: https://www.courtlistener.com/opinion/78100/turner-v-burnside/ - U.S. Department of Justice, 1297026, U.S. Department of Justice, Civil Rights Division [official_report, primary] URL: https://www.justice.gov/crt/case-document/file/1297026/download - U.S. Department of Justice, dl, U.S. Department of Justice [official_report, primary] URL: https://www.justice.gov/opa/press-release/file/1150276/dl - United States v. State of Alabama, 2026-08-31 (court record via CourtListener), CourtListener (2026-08-31) [legal_document, primary] URL: https://www.courtlistener.com/docket/18729285/ - United States v. State of Florida, Court of Appeals for the Eleventh Circuit, 2026-03-31 (court record via CourtListener), CourtListener (2026-03-31) [legal_document, primary] URL: https://www.courtlistener.com/opinion/10830722/united-states-v-state-of-florida/ - Victor Parsons v. Charles Ryan, U.S. Court of Appeals, 9th Circuit, 2014-06-05 (court record via CourtListener), CourtListener (2014-06-05) [legal_document, primary] URL: https://www.courtlistener.com/opinion/2677279/victor-parsons-v-charles-ryan/ - Wal-Mart Stores, Inc. v. Dukes, Supreme Court of the United States, 2011-06-20 (court record via CourtListener), CourtListener (2011-06-20) [legal_document, primary] URL: https://www.courtlistener.com/opinion/219618/wal-mart-stores-inc-v-dukes/ - Walker v. Schult, Court of Appeals for the Second Circuit, 2013-05-23 (court record via CourtListener), CourtListener (2013-05-23) [legal_document, primary] URL: https://www.courtlistener.com/opinion/868764/walker-v-schult/ - Walter Melton v. David Abston, Court of Appeals for the Eleventh Circuit, 2016-11-18 (court record via CourtListener), CourtListener (2016-11-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4322903/walter-melton-v-david-abston/ - Willie Balle v. David Kennedy, Court of Appeals for the Seventh Circuit, 2023-07-14 (court record via CourtListener), CourtListener (2023-07-14) [legal_document, primary] URL: https://www.courtlistener.com/opinion/9415207/willie-balle-v-david-kennedy/ - Wilson v. Seiter | 501 U.S. 294 (1991) | Justia U.S. Supreme Court Center, Justia (via Internet Archive) (1991-01-01) [legal_document, primary] URL: https://web.archive.org/web/20260112012920id_/https://supreme.justia.com/cases/federal/us/501/294/ - Wilson v. Seiter, Supreme Court of the United States, 1991-06-17 (court record via CourtListener), CourtListener (1991-06-17) [legal_document, primary] URL: https://www.courtlistener.com/opinion/112626/wilson-v-seiter/ - Woodford v. Ngo, Supreme Court of the United States, 2006-06-22 (court record via CourtListener), CourtListener (2006-06-22) [legal_document, primary] URL: https://www.courtlistener.com/opinion/145635/woodford-v-ngo/ - Yates v. Collier, 868 F.3d 354 (5th Cir. 2017), U.S. Court of Appeals for the Fifth Circuit (2017-08-18) [legal_document, primary] URL: https://www.courtlistener.com/opinion/4420346/david-bailey-v-bryan-collier/