Case: Doty v. County of Lassen

2:89-cv-01019 | U.S. District Court for the Eastern District of California

Filed Date: July 25, 1989

Closed Date: 1994

Clearinghouse coding complete

Case Summary

On July 25, 1989, prisoners at the old Lassen County Jail ("Old Jail") filed a class action lawsuit in the U.S. District Court for the Eastern District of California against the County of Lassen and the Sheriff of the County of Lassen. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging that conditions in the Old Jail violated the First, Fourth and Eighth Amendments of the Constitution of the United States as applied to the…

On July 25, 1989, prisoners at the old Lassen County Jail ("Old Jail") filed a class action lawsuit in the U.S. District Court for the Eastern District of California against the County of Lassen and the Sheriff of the County of Lassen. The plaintiffs, represented by the Prisoner Rights Union and private counsel, brought suit under 42 U.S.C. § 1983, alleging that conditions in the Old Jail violated the First, Fourth and Eighth Amendments of the Constitution of the United States as applied to the states through the Fourteenth Amendment. Among other things, they alleged overcrowding, inadequate clothing, inadequate medical, dental and mental health care, inadequate privacy for conversations with attorneys, and unequal access to programs for women prisoners. Plaintiffs sought a broad set of injunctive remedies.

When the suit was filed, Lassen County was developing and implementing plans for construction of a new, much larger jail ("New Jail").

On October 17, 1989, the District Court approved a stipulated order preliminarily enjoining certain Old Jail conditions. Pursuant to the stipulated order, the County agreed to: (1) limit inmate population at the Old Jail to forty-one inmates; (2) limit the temporary holding cell's population to the rated capacity; (3) limit time spent in the temporary holding cell to eight hours; (4) comply with California law in its use of the detoxification facility; (5) provide all prisoners with a permanent bed appropriate to his/her classification; and (6) provide all prisoners with daily access to the "program room" and outdoor recreation.

Beginning on July 16, 1990, the case was tried before Magistrate Judge John F. Moulds. The trial concluded in September 1990. On July 1, 1991, the New Jail opened and the County ceased using the Old Jail.

On August 1, 1991, Magistrate Judge Moulds entered his 129-page findings and recommendations. On September 17, 1991, District Judge Lawrence K. Karlton entered an order adopting the findings and recommendations, with one minor modification. The order granted the following relief: (1) For a period of one year, the County was prohibited from exceeding the established inmate capacities at the Old Jail or the New Jail; (2) The County was required to "modify" and follow written policies regarding access to the jail law library; (3) The County was required to clarify the procedures for staff handling of prisoners demonstrating a mental disorder; (4) The County was required to develop a procedure for ensuring a timely response to an inmate's request for mental health care. All further requests for relief were denied. On October 9, 1991, Judge Karlton entered a judgment. On November 7, 1991, the defendants filed their notice of appeal from the judgment.

The attorney's fees litigation then commenced, with both sides seeking attorney's fees. On March 30, 1993, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue. On April 20, 1993, Judge Karlton filed an order adopting the finding and recommendations in full. This order granted the plaintiffs some of the attorney's fees they had sought, for a total of $219,027.61, and denied the defendants' request for fees. On April 27, 1993, Judge Karlton entered his Judgment pursuant to the attorney's fees order. On April 28, 1993, the appellants filed their notice of appeal from the attorney's fees order, and the award was stayed pending appeal.

On October 6, 1994, a three-judge panel of the Ninth Circuit (Circuit Judges Arthur L. Alarcon and Ferdinand F. Fernandez and District Judge Stephen V. Wilson, sitting by designation) reversed the District Court's decision to grant permanent injunctive relief but affirmed its decision that attorney's fees were appropriate. Doty v. Cnty. of Lassen, 37 F.3d 540 (9th Cir. 1994). The panel, in an opinion by Judge Wilson, found that the injunction as a whole was erroneous because there was no evidence of constitutional violation at the New Jail. It also found, however, that since the plaintiffs had succeeded in obtaining a preliminary injunction and had catalyzed other reforms at the jails, they were "prevailing parties" under 42 U.S.C. § 1988 and could be awarded reasonable attorney's fees; it therefore vacated the District Court's award and remanded for redetermination in light of plaintiffs' limited success.

On remand, Magistrate Judge Moulds filed findings and recommendations on the attorney's fees issue on July 26, 1995, and Judge Karlton adopted them in full on September 19, awarding plaintiffs a total of $83,616.75. On the same day, Judge Karlton entered judgment in favor of the defendants per the order of the Court of Appeals.

(This summary is adapted in part from the Appeals Court's discussion of the background of the case. See Doty, 37 F.3d at 542.)

Summary Authors

Christopher Schad (7/11/2012)

People


Judge(s)

Karlton, Lawrence K. (California)

Moulds, John F. (California)

Wilson, Stephen Victor (California)

Attorneys(s) for Plaintiff

Abbott, Harold L. (California)

Berry, Gina S. (California)

Comiskey, Paul Wayne (California)

Derevan, Richard (California)

Eisen, Jay-Allen (California)

Fabricant, Deborah (California)

Herman, Richard P. (California)

Judge(s)

Karlton, Lawrence K. (California)

Moulds, John F. (California)

Wilson, Stephen Victor (California)

Attorneys(s) for Plaintiff

Abbott, Harold L. (California)

Berry, Gina S. (California)

Comiskey, Paul Wayne (California)

Derevan, Richard (California)

Eisen, Jay-Allen (California)

Fabricant, Deborah (California)

Herman, Richard P. (California)

Persons, Paul Turner (California)

Stormer, Dan Lewis (California)

Attorneys(s) for Defendant

Franklin, Roberta L. (California)

Woodlock, Lawrence T. (California)

Documents in the Clearinghouse

Document

Docket (PACER)

March 12, 1996 Docket

Complaint for Injunctive Relief Class Action

Doty v. Lassen

June 25, 1989 Complaint
180

Findings and Recommendations

Doty v. Lassen

Sept. 13, 1991 Order/Opinion
185

Order

Doty v. Lassen

Sept. 19, 1991 Order/Opinion
192

Judgment in a Civil Case

Doty v. Lassen

Oct. 9, 1991 Order/Opinion

[Ninth Circuit] Opinion [Vacating the District Court's Injunction]

U. S. Court of Appeals for the Ninth Circuit

37 F.3d 540

Oct. 6, 1994 Order/Opinion

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: California

Case Type(s):

Jail Conditions

Special Collection(s):

California Jail Population Caps

Key Dates

Filing Date: July 25, 1989

Closing Date: 1994

Case Ongoing: No

Plaintiffs

Plaintiff Description:

prisoners in the Lassen County jails

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Hadsell, Stormer & Renick

Prisoners Rights Union

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

County of Lassen (Lassen), County

Defendant Type(s):

Corrections

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Freedom of speech/association

Unreasonable search and seizure

Availably Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: $83,616.75 (atty fees)

Order Duration: 1989 - 1994

Content of Injunction:

Preliminary relief granted

Issues

General:

Access to lawyers or judicial system

Bathing and hygiene

Conditions of confinement

Food service / nutrition / hydration

Grievance Procedures

Law library access

Record-keeping

Recreation / Exercise

Staff (number, training, qualifications, wages)

Crowding:

Crowding / caseload

Pre-PLRA Population Cap

Discrimination-basis:

Disability (inc. reasonable accommodations)

Sex discrimination

Disability:

Mental impairment

Medical/Mental Health:

Medical care, general

Mental health care, general

Type of Facility:

Government-run