Case: Moorhead v. Lane
2:86-cv-02020 | U.S. District Court for the Central District of Illinois
Filed Date: Jan. 21, 1986
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Case Summary
This case was a civil rights class action against Illinois prison officials. It alleged discrimination against incarcerated women in housing, training, and pay. It culminated in a consent decree which required the construction of an all-women minimum-security prison and a “good faith” effort to reform education and vocational programs for women.
Six incarcerated women filed a class action complaint on January 21, 1986, in the U.S. District Court for the Central District of Illinois. Under 42 U.S.C. § 1983, they sought declaratory and injunctive relief for violations of the Fourteenth Amendment’s Equal Protection Clause. Plaintiffs were represented by the ACLU of Illinois and private counsel. Defendants were two officials from the Illinois Department of Corrections. Judge Harold A. Baker was assigned to the case.
As the available documents in this case were limited, some additional information was gathered from a 1993 publication from the ACLU’s National Prison Project, a 1994 article from the Chicago Tribune, and a 2009 article from the Daily Journal.
Their case had three main allegations:
- Illinois did not have a women-only minimum-security prison at the time of filing. As such, many incarcerated women were forced to complete their sentences at the maximum-security Dwight Correctional Center, the only all-women prison in the state. This subjected many incarcerated women to heightened risks, surveillance, and controls that were disproportionate to their sentences. Additionally, Illinois’ prisons were becoming increasingly overcrowded as the state legislature was actively boosting sentences and creating new classes of crime.
- Illinois failed to provide incarcerated women with adequate vocational or educational programs. Male inmates were offered classes on computers, in mechanics, or electrical work. In comparison, women inmates were limited to classes such as sewing, cosmetology, and ““ridiculous secretarial classes on manual typewriters that didn't even work.” Plaintiffs argued that these courses failed to prepare them for the workforce.
- Incarcerated males were unfairly paid more than female inmates for the same or similar jobs.
On April 29, 1989, the court issued an order in response to a discovery dispute. Defendants sought to compel plaintiffs to answer questions on discussions they had with two law clerks employed at the prison. Plaintiffs argued that attorney-client privilege applied as the law clerks effectively served as “jailhouse attorn[ies].” However, the court ultimately concluded that privilege did not apply as the law clerks were not licensed attorneys. 125 F.R.D. 680.
On March 25, 1991, both sides moved for preliminary approval of a consent decree. This approval was granted two days later. On May 1, 1991, the consent decree was formally entered, and the case was dismissed. This decree included the following terms:
- Illinois was required to build an all-women minimum-security prison by 1993. This facility was required to have at least 200 beds.
- Illinois was required to make a “good faith” effort to offer more programs to women. This would include sending all 1,230 women incarcerated in the state prison system a questionnaire asking for potential vocational and educational programs.
- Illinois would pay $20,000 in legal fees to the plaintiffs’ lawyers. However, plaintiffs stated that they had paid over $200,000 in legal fees in the case at that time.
- Plaintiffs would drop allegations concerning unfair payment.
- The court would monitor progress until at least June 30, 1994.
The consent decree led to the construction of the all-women Kankakee Minimum Security Unit in 1991. This facility closed in May 2011 as the result of large state budget cuts. At the time, there was no other minimum security facility for women. An ACLU official stated that it was unclear whether this violated the 1991 consent decree as it "didn't require any particular prison to stay open[.]" However, as of January 2023, the Decatur Correctional Center was designated as a minimum security facility for women.
As of January 28, 2023, no further actions have occurred in this case except for two third-party requests for documents.
Summary Authors
Eric Gripp (1/20/2023)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/9213202/parties/high-v-lane/
Baker, Harold Albert (Illinois)
Epstein, Bennett L. (Illinois)
Grossman, Harvey (Illinois)
Kennedy, John Francis (Illinois)
Nijman, Jennifer T. (Illinois)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/9213202/high-v-lane/
Last updated June 19, 2026, 6:31 a.m.
Case Details
State / Territory:
Case Type(s):
Key Dates
Filing Date: Jan. 21, 1986
Case Ongoing: Perhaps, but long-dormant
Plaintiffs
Plaintiff Description:
Six incarcerated women who were housed at the Illinois run Dwight Correctional Center.
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
State
Illinois Department of Corrections
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Other Dockets:
Central District of Illinois 2:86-cv-02020
Available Documents:
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Content of Injunction:
Goals (e.g., for hiring, admissions)
Amount Defendant Pays: $20,000
Issues
General/Misc.:
Discrimination Area:
Discrimination Basis:
Affected Sex/Gender(s):
Jails, Prisons, Detention Centers, and Other Institutions:
Placement in detention facilities
Case Summary of Moorhead v. Lane, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/14869/ (last updated 1/20/2023).