Case: Johnson v. Heffron

1:79-cv-00045 | U.S. District Court for the Western District of Michigan

Filed Date: Jan. 24, 1979

Closed Date: Sept. 19, 1996

Clearinghouse coding complete

Case Summary

In 1979, the plaintiffs, pretrial detainees, filed a class action lawsuit in the U.S. District Court for the Western District of Michigan against the Kent County Sheriff and the Kent County Correctional Facility (KCCF). The plaintiffs, represented by Legal Aid of Western Michigan and private counsel, alleged that the jail conditions violated their constitutional rights under the First, Eighth, and Fourteenth Amendments. In the midst of this litigation, the District Court identified a ''woeful …

In 1979, the plaintiffs, pretrial detainees, filed a class action lawsuit in the U.S. District Court for the Western District of Michigan against the Kent County Sheriff and the Kent County Correctional Facility (KCCF). The plaintiffs, represented by Legal Aid of Western Michigan and private counsel, alleged that the jail conditions violated their constitutional rights under the First, Eighth, and Fourteenth Amendments. In the midst of this litigation, the District Court identified a ''woeful overpopulation" problem at KCCF, with an average daily population of

466 in 1982 in a facility rated for 451 occupants. The facility exceeded maximum capacity

for 332 days of that year.

In 1982, the parties agreed to a partial consent decree, addressing among other things the problem of overcrowding at KCCF. The consent decree required KCCF not to exceed 90% of maximum capacity. The consent decree was amended in 1985 to allow for 95% maximum capacity and to create procedures initiated when the jail population exceeded 95% capacity for three consecutive days.

In 1994 KCCF was fully renovated, increasing the total number of beds from 573 to 994. The defendants filed a motion to vacate the previous consent judgment. On March 20, 1995, the District Court (Judge Richard A. Enslen) denied the motion. The court held that, in neglecting to provide specific data about the overpopulation problem, the defendants had failed to show that the goals of the consent decree had been achieved.

In May 1995, the defendants made a renewed motion to vacate the consent judgment, this time supporting their motion with data showing that, since the 1994 renovation, KCCF had been under 95% capacity 98% of the time. The District Court again denied the defendants' motion. The court held that there was an insufficient buffer to assure that overcrowding would not again become a problem at KCCF if the consent decree was vacated. In addition, the court questioned the defendants' motivations for dissolving a capacity limit the defendants claimed would not be exceeded in the future. The defendants appealed.

On July 9, 1996, the Court of Appeals for the Sixth Circuit (Judge David A. Nelson) reversed and remanded, finding that the District Court had abused its discretion in denying the motion, citing the defendants' record of substantial compliance with the consent decree and their good faith efforts to improve conditions at KCCF. The court remanded for entry of relief from judgment. Johnson v. Heffron, 88 F.3d 404 (6th Cir. 1996).

On remand, the District Court granted the defendants' motion to vacate the consent decree on August 7, 1996.

The plaintiffs filed a motion for attorney's fees and costs; this was apparently settled by a stipulation, which was entered in the PACER docket on September 19, 1996.

Summary Authors

Chris Sullivan (8/26/2005)

People


Judge(s)

Enslen, Richard Alan (Michigan)

Kennedy, Cornelia Groefsema (Michigan)

Attorneys(s) for Plaintiff

Archer, Robert W. (Michigan)

Berger, Joel (New York)

Chambers, Julius LeVonne (New York)

Emmel, Nancy E. (Missouri)

Meeks, John E. (Michigan)

Nelson, Michael O. (Michigan)

Sindel, Richard H. (Missouri)

Attorneys(s) for Defendant

Decker, Teresa S. (Michigan)

Judge(s)

Enslen, Richard Alan (Michigan)

Kennedy, Cornelia Groefsema (Michigan)

Attorneys(s) for Plaintiff

Archer, Robert W. (Michigan)

Berger, Joel (New York)

Chambers, Julius LeVonne (New York)

Emmel, Nancy E. (Missouri)

Meeks, John E. (Michigan)

Nelson, Michael O. (Michigan)

Sindel, Richard H. (Missouri)

Attorneys(s) for Defendant

Decker, Teresa S. (Michigan)

DeWitt, Jon F. (Michigan)

Documents in the Clearinghouse

Document

Docket [PACER]

Jan. 24, 1979 Docket

Reported Opinion

U. S. Court of Appeals for the Sixth Circuit

88 F.3d 404

July 9, 1996 Order/Opinion

Docket

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

Docket sheet not available via the Clearinghouse.

State / Territory: Michigan

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Jan. 24, 1979

Closing Date: Sept. 19, 1996

Case Ongoing: No

Plaintiffs

Plaintiff Description:

pretrail detainees in Kent County, Michigan

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Kent County Correctional Facility (Kent), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Equal Protection

Availably Documents:

Trial Court Docket

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1979 - 1996

Issues

Crowding:

Crowding / caseload

Type of Facility:

Government-run