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Remedies Keyed to Tabb, 8th
Brown v. Plata
Citation:
131 S. Ct. 1910, 563 U.S. 493 (2011)Facts
California’s prison system operated at approximately 200% of design capacity for at least 11 years, with prisoners crammed into gymnasiums monitored by minimal staff and sharing inadequate toilet facilities. The overcrowding caused severe deficiencies in medical and mental health care. Vacancy rates for medical staff reached 20% for surgeons and 54.1% for psychiatrists, with insufficient clinical space even if positions were filled. Suicidal inmates were held in telephone-booth-sized cages without toilets for extended periods. Wait times for mental health care reached 12 months. California’s suicide rate was 80% higher than the national prison average, with 72.1% of suicides deemed preventable. Prisoners experienced significant delays in medical treatment, resulting in preventable deaths. The Coleman Special Master (appointed 1995) and Plata Receiver (appointed 2005) both reported that overcrowding prevented effective remediation despite years of effort. After extensive trial proceedings including 14 days of testimony, the three-judge court found that overcrowding was the primary cause of constitutional violations and that no remedy short of population reduction would be effective.
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