Case: Ercoli v. County of Tuolumne

On October 23, 1990, several prisoners at the Tuolumne County Jail filed a class action in the U.S. District Court for the Eastern District of California against the County of Tuolumne. The plaintiffs, represented by the Prisoner Rights Union and private counsel, filed suit under 42 U.S.C. § 1983, challenging the constitutionality of their conditions of confinement. Specifically, they alleged problems with overcrowding, cleanliness, ventilation, heating and cooling, exercise, the law library, prompt determination of probable cause, and equal access to programs for female prisoners. The plaintiffs sought declaratory and injunctive relief, and on October 29, 1990, also applied for a temporary restraining order.

On December 18, 1990, the District Court (Magistrate Judge John F. Moulds) directed the County to submit a plan within 10 days to ensure effective communication between prisoners and correctional officers and to submit a proposed order allowing prisoners adequate access to law library.

On the same day, Magistrate Judge Moulds submitted a report recommending that the Court certify the plaintiffs' proposed class, enjoin the County from bedding prisoners on the floor or adding additional beds to the jail pending the outcome of the case, and authorize the sheriff to release prisoners when the jail is within 10 beds of being filled and not to accept new prisoners when all beds are filled. In all other respects, he recommended that preliminary relief be denied. The Court (Senior Judge Edward D. Price) adopted the report in full on January 16, 1991.

On December 26, 1990, plaintiffs filed a motion for a preliminary injunction. Later, on July 9, 1991, the County filed a motion for partial summary judgment. On February 25, 1992, the Court (Magistrate Judge Moulds) issued an order on the motions pending before it. It ordered that the plaintiffs' motion for a preliminary injunction on the issue of the law library be granted in part but that their motion for a temporary restraining order be denied. It also ordered that the County's motion for partial summary judgment on the issues of general jail population, exercise, and prompt determination of probable cause be granted, but that the motion be otherwise denied.

On March 6, 1992, plaintiffs filed a motion for reconsideration of the Court's grant of summary judgment to the County on the issue of exercise, and on April 21, the Court (Magistrate Judge Moulds) granted that motion, leaving that issue for trial. The trial began on May 4, 1992, and lasted twelve days.

A letter to the Court from the County on September 10, 1992, indicates that ventilation and heating and cooling systems in the jail had been improved.

Meanwhile, the parties had begun negotiations to settle in March 1992, and they lodged a settlement agreement with the Court on December 8, 1994. The Court (Magistrate Judge Moulds) approved the settlement (the content of which is unfortunately unclear from the docket) on March 22, 1995, dismissed the case on April 5, and ordered the County to pay plaintiffs' attorneys' fees and costs in the amount of $167,437.19 on March 27, 1996.

The Court (Magistrate Judge Moulds) had also issued an order directing the County to make certain additions to the law library at the jail on December 21, 1994. The County appealed this order, and on March 27, 1997, a three-judge panel of the Ninth Circuit (Judge James R. Browning, Judge William C. Canby, Jr., and Judge Cynthia H. Hall) vacated the decision and remanded to the District Court to determine whether there was actual injury to the plaintiffs and to limit the scope of its relief to that injury. Ercoli v. Cnty. of Tuolumne, 110 F.3d 68 (9th Cir. 1997).

In response, the parties reached a settlement on the issue of the law library, and the Court (Magistrate Judge Moulds) approved it on November 26, 1997, awarding a further $130,000 to plaintiffs in attorneys' fees. The case was definitively closed on February 6, 1998.