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Civil Procedure Keyed to Subrin
Brown v. Plata
Citation:563 U.S. 493 (2011)
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Severe overcrowding of California’s prisons, together with deficient mental health and medical care and lack of state resources, led to the filing of two class actions. The first, Coleman v. Brown, involved prisoners with serious mental disorders. In Coleman, a district court found “overwhelming evidence of the systematic failure to deliver necessary care” to inmates. The second case, Brown v. Plata, involved a class of prisoners with serious medical conditions. In that case, the State conceded that deficiencies in prisons violated the Eighth Amendment’s prohibition against cruel and unusual punishments. The court also found that the California “prison medical care system is broken beyond repair,” resulting in an “unconscionable degree of suffering and death.” The Coleman and Plata plaintiffs moved their respective district courts to convene a three-judge court empowered under the Prison Litigation Reform Act of 1995 (PRLA) to order reductions in the prison population. After extensive testimony and evidence, the three-judge court ordered California to submit a plan to reduce its prison population to 137.5 percent of the prisons’ design capacity within two years which would result in the release of 38,000 to 46,000 inmates. California appealed. The U.S. Supreme Court granted certiorari to review.
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