Warning

Info

Table of Contents
Pilea, HLS '24 |

0 0

Back to briefs

Brown v. Plata

(2011)

Supreme Court of the United States - 131 S. Ct. 1910

tl;dr:

The severe overcrowding of CA prisons violates the Eighth Amendment, and so the Court issuing an order to remedy the situation is valid.

Video Summary


Case Summary

In Brown v. Plata (2011), the U.S. Supreme Court made a crucial decision concerning prison overcrowding and prisoners' rights. The case involved California being directed to decrease its prison population by a three-judge district court, to address two violations of the prohibition of cruel and unusual punishments under the Eighth Amendment. Two federal class actions (Coleman v. Brown and Plata v. Brown) had been filed, claiming that prisoners did not receive proper care for serious mental and medical conditions. Despite remedial injunctions, the state failed to comply for years.

Under the Prison Litigation Reform Act (PLRA) of 1995, the plaintiffs called for a three-judge court to order population reductions. This court combined the two cases and ordered California to decrease its prison population within two years. The state appealed to the Supreme Court, questioning the necessity of the three-judge court's decision.

The Supreme Court upheld the order by a 5-4 vote. They concluded that overcrowding caused inadequate medical care and that no other relief would address the constitutional violations. They found the order to adhere to the PLRA and prioritize public safety. Two dissenting opinions disagreed, claiming mismanagement or incompetence caused inadequate healthcare and arguing that the order violated the PLRA.

This case was significant in tackling prison overcrowding and clarifying federal judicial power concerning the PLRA.

ICRAIssue, Conclusion, Rule, Analysis for Brown v. Plata

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Brown v. Plata case brief summary.

Enjoy unlimited access with our 14-day free trial.

Facts & HoldingBrown v. Plata case brief facts & holding

Facts:Severe overcrowding of CA prisons + extremely deficient mental health/medical...

Holding:"Courts may not allow constitutional violations to continue simply because...

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Brown v. Plata case brief summary.

Enjoy unlimited access with our 14-day free trial.

DeepDiveHighlight a legal term to see the definition

Font size -+
Brown v. Plata | Case Brief DeepDive
Majority opinion, author: Justice Kennedy
Level 1
Click below 👇 to DeepDive

The Plata v. Brown case involves constitutional violations in California's prison system, specifically violations of the Cruel and Unusual Punishments Clause guaranteed by the Due Process Clause of the Fourteenth Amendment. The Supreme Court affirmed the three-judge court's order to limit the population in California's overcrowded prisons, which violates prisoners' constitutional rights. The court ordered California to reduce its prison population to 137.5% of the prisons' design capacity within two years, requiring a population reduction of 38,000 to 46,000 persons. The PLRA restricts the circumstances in which a court may enter an order that reduces or limits the prison population, but the order in this case can be achieved by increasing prison capacity or transferring prisoners to other facilities. The three-judge court must determine by clear and convincing evidence that overcrowding is the primary cause of the violation of a federal right and that no other relief will remedy the violation. The relief granted must be narrowly drawn and extend no further than necessary to correct the violation of the federal right of a particular plaintiff or plaintiffs. The State argues that it was an error to convene the three-judge court without giving it more time to comply with prior orders in Coleman and Plata. The Supreme Court has the authority to review the decision to convene a three-judge court, despite the argument that the State should have appealed the orders of the District Courts in the Court of Appeals first.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Brown v. Plata case brief summary.

Enjoy unlimited access with our 14-day free trial.

Dissenting opinion, author: Justice Scalia
Level 1
Click below 👇 to DeepDive

The court's decision to release 46,000 convicted criminals is criticized for violating the Prison Litigation Reform Act of 1995. Structural injunctions that involve judges in policymaking outside of their legal role are also opposed. Judges are urged to exercise restraint in cases involving state penal systems and defer to appropriate prison authorities. The PLRA mandates that relief be narrow and limited to correct the violation of Federal rights in the least intrusive way possible. Structural injunctions, particularly prisoner-release orders, are seen as raising separation-of-powers concerns and exceeding the historical role and institutional capability of courts. In this case, the District Court's order to release 46,000 prisoners in California is deemed to extend further than necessary to correct the violation of the federal right of a particular plaintiff or plaintiffs and is therefore forbidden by the PLRA and defies the proper role of judges.

Dissenting opinion, author: Justice Alito
Level 1
Click below 👇 to DeepDive

The dissenting opinion argues that the three-judge court exceeded its authority under the Prison Litigation Reform Act of 1995 by ordering the release of 46,000 inmates without adequately establishing a violation of the Constitution and without considering evidence of present conditions in California prisons. The relief must be narrowly tailored to correct the violation of a federal right and be the least intrusive means necessary. The majority of the Supreme Court relied on outdated statistics and anecdotal evidence when assessing the current state of the California prison system. The California prison health care system has multiple issues, but improvements can be made without compromising public safety, such as targeted reductions in the State's prison population and transferring prisoners to out-of-state facilities. The three-judge court's conclusion that releasing 46,000 criminals would improve public safety is debatable, and the State had informed the court that reducing the prison population to 137.5% within a two-year period would compromise public safety.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Brown v. Plata case brief summary.

Enjoy unlimited access with our 14-day free trial.

🤯 High points 🤯Key points contributed by students on LSD

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Brown v. Plata case brief summary.

Enjoy unlimited access with our 14-day free trial.

LSD+ Case Briefs

Features

  • DeepDive for detailed case analysis
  • Over 50,000 existing case briefs
  • Instant briefs for another 6,000,000 cases
  • Highlight dictionary for legal term definitions
  • Social learning with chat and high points

Over 50,000 Cases Briefed

LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.

14-Day Free Trial

Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.

Integrated Legal Dictionary

Lawyers and judges love to use big words. And Latin, for some reason.

Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.

DeepDive

DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.

Brief anything. Instantly.

Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.

Social Learning with Chat and High Points

Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.

Real-Time Brief Feedback

Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.

Brown v. Plata

Chat for Brown v. Plata
brief-316
👍 Chat vibe: 0 👎
Help us make LSD better!
Tell us what's important to you
LSD+ is ad-free, with DMs, discounts, case briefs & more.