Case: Owens v. Robinson

2:75-cv-00412 | U.S. District Court for the Western District of Pennsylvania

Filed Date: April 4, 1975

Closed Date: 1996

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Case Summary

In 1975 a former inmate at the Allegheny County Jail in Pittsburgh, Pennsylvania, filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Western District of Pennsylvania against jail officials alleging that the conditions of confinement at the jail violated his constitutional rights. In 1976 Neighborhood Legal Services (NLS) filed a class action lawsuit in the U.S. District Court for the Western District of Pennsylvania, on behalf of all inmates of the Allegheny County Jail s…

In 1975 a former inmate at the Allegheny County Jail in Pittsburgh, Pennsylvania, filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Western District of Pennsylvania against jail officials alleging that the conditions of confinement at the jail violated his constitutional rights. In 1976 Neighborhood Legal Services (NLS) filed a class action lawsuit in the U.S. District Court for the Western District of Pennsylvania, on behalf of all inmates of the Allegheny County Jail seeking a declaratory judgment that the conditions at the jail violated the inmates' constitutional rights. The two cases were consolidated and certified as a class action with NLS representing the class. On January 4, 1978, the court (Judge Maurice Cohill) found that many of the jail's conditions were unconstitutional. Owens-El v. Robinson, 442 F.Supp. 1368 (W.D. Penn. 1978). On October 11, 1978, after receiving the opinion of the appointed Court Advisor, the court (Judge Cohill) entered a final order, directing the jail to maintain adequate numbers of guards, prepare a written program for daily house cleaning, to furnish each cell with a 100 watt light bulb, to distribute clean clothing, bedding and toiletries to inmates upon arrival, to revise the rules manual and to inform inmates of the rules, to train nurses in handling mental problems, to maintain a appropriate number of telephones, and to provide a law library. Owens-El v. Robinson, 547 F.Supp. 984 (W.D. Penn. 1978). The inmates appealed on the issues of contact visits, methadone treatment and psychiatric care. On December 28, 1979, the Third Circuit Court of Appeals (Judge Max Rosenn) affirmed the district court on the issues of contact visits and methadone treatment, but remanded on the issue of psychiatric care. Inmates of Allegheny County Jail v. Pierce, 612 F.2d 754 (3rd Cir. 1979). On remand, the district court (Judge Cohill) found the psychiatric care at the jail was below the minimum standard, and ordered that the jail hire a psychiatric program administrator, hire psychiatrist, establish a screening center for new admitees, establish a separate area for the mentally ill, and produce written procedures for mental health care. Inmates of Allegheny County Jail v. Peirce, 487 F.Supp. 638 (W.D. Penn. 1980).

On October 16, 1980, the court (Judge Cohill) denied the original litigant's motion for rehearing because the NLS had been monitoring the conditions at the jail, and was adequately representing the class of litigants. Owens-El v. Robinson, 498 F.Supp. 877 (W.D. Penn. 1980). On December 9, 1982, the Third Circuit Court of Appeals (Judge Francis Van Dusen) affirmed. Owens-El v. Robinson, 694 F.2d 941 (3rd Cir. 1982).

In April 1983, inmates filed two motions in the District Court alleging that previous court orders were not being met. After touring the jail, the court (Judge Cohill) found that the jail had violated many of the provisions of the previous orders including psychiatric care, staffing, cleanliness, use of restraints, use of "the hole", and female access to a law library. Inmates of Allegheny County Jail v. Wecht, 565 F.Supp. 1278 (W.D. Penn. 1983). The court also found that overcrowding at the jail constituted a constitutional violation. The court ordered that these conditions be monitored for the indefinite future, that the jail submit a plan to remedy problems with the mentally ill, and that the jail reduce population over a period of months. On October 20, 1983 the court (Judge Cohill) denied the jail's motion for an extension of time to comply with the population cap and ordered that the only federal inmates who were on trial be housed in the jail, and that prisoners held on the lowest amount of bail be released until the population cap was met. Inmates of Allegheny County Jail v. Wecht, 573 F.Supp. 454 (W.D. Penn. 1983). On December 30, 1983, the court ordered the jail to pay a sanction of $5,000 for each prisoner released from the jail in order to comply with the population limits. On February 28, 1984, the court denied the jail's motion to modify the population cap. On January 29, 1985, the Third Circuit Court of Appeals (Judge John Gibbons) affirmed the denial of the motion for modification but vacated the order requiring the jail to pay sanctions. Inmates of Allegheny County Jail v. Wecht, 754 F.2d 120 (3rd Cir. 1985).

In 1985 inmates sought additional relief, claiming that the practice of keeping the women who had been judicially committed to the Allegheny County jail in the crowded city lockup because of the population cap violated the court's order. On June 26, 1985, the district court (Judge Cohill) found that the conditions at the city lockup were inadequate to hold inmates for long periods of time, and that use of the lockup was a violation of the court's order. Inmates of Allegheny County Jail v. Wecht, 612 F.Supp. 874 (W.D. Penn. 1985).

In 1988, inmates at the county jail sought sanctions against the jail for overcrowding and other unconstitutional conditions. On November 17, 1988, the district court (Judge Cohill) found that the old jail facility was constitutionally inadequate, the mental health care at the jail was inadequate, and that the population caps had been consciously violated. Inmates of the Allegheny County Jail v. Wecht, 699 F.Supp. 1137 (W.D. Penn. 1988). The court ordered that the jail be closed, a new jail with a capacity of at least 900 inmates be planned, and no prisoners be housed at the main jail after June 30, 1990. The court also fined the defendants $25,000, and imposed the same fine for each future month the population caps were exceeded.

On May 4, 1989, the Third Circuit Court of Appeals (Judge Gibbons) affirmed the judgment of the district court on the issues of sanctions and closing the jail but found that the order to plan a new jail was not appealable because it was not sufficiently specific. Inmates of the Allegheny County Jail v. Wecht, 874 F.2d 147 (3rd Cir. 1989). On November 6, 1989 the Supreme Court granted certiorari and vacated the judgment, remanding the case back to the Third Circuit Court of Appeals. Wecht v. Inmates of the Allegheny County Jail, 493 U.S. 948 (1989). On January 8, 1990, the Third Circuit Court of Appeals (Judge Gibbons) remanded with instructions to vacate the judgment to build a new jail, on the grounds that it was rendered moot by a July 7, 1989, stipulation order relieving the County of the duty to build a new jail so long as it significantly improved the old jail. Inmates of the Allegheny County Jail v. Wecht, 893 F.2d 33 (3rd Cir. 1990).

On July 17, 1989, the district court issued sanctions against the county officials, for violations of the population cap. On April 19, 1990, the Third Circuit Court of Appeals (Judge Leon Higginbotham) affirmed the sanctions but vacated an order awarding attorney's fees to the plaintiffs. Inmates of the Allegheny County Jail v. Wecht, 901 F.2d 1191 (3rd Cir. 1990).

The County decided to build a new jail, and under the stipulation order, the jail was to be completed by June 30, 1992. In 1992, the County made motions in the district court to extend the time for completion of the new jail, to increase the population cap, and to modify the stipulation order so that the county could implement an Intensive Case Management Plan for the mentally ill as opposed to building a separate facility. On June 26, 1992, the district court (Judge Cohill) granted all three motions. Inmates of the Allegheny County Jail v. Wecht, 797 F.Supp. 428 (W.D. Penn. 1992). The court gave the county until December 1, 1994, to have the new jail operational. On December 23, 1993, the Third Circuit Court of Appeals, in a decision without opinion, reversed the district court. Inmates of Allegheny County Jail v. Wecht, 17 F.3d 1430 (3rd Cir. 1993).

On March 30, 1994, the district court (Judge Cohill) issued an order sua sponte, vacating the order imposing sanctions on the jail for breach of the population cap, and returned the fines collected to the County to assist with the cost of the new jail or drug rehabilitation programs. Inmates of the Allegheny County Jail v. Wecht, 848 F.Supp. 52 (W.D. Penn. 1994).

Summary Authors

Jaclyn Adams (3/18/2006)

Related Cases

County of Allegheny v. Commonwealth of Pennsylvania, Pennsylvania state trial court (1983)

People


Judge(s)

Alito, Samuel A. Jr. (New Jersey)

Becker, Edward Roy (Pennsylvania)

Cohill, Maurice Blanchard Jr. (Pennsylvania)

Cowen, Robert E. (New Jersey)

Gibbons, John Joseph (Pennsylvania)

Greenberg, Morton Ira (New Jersey)

Higginbotham, Aloyisus Leon Jr. (Pennsylvania)

Lewis, Timothy K. (Pennsylvania)

Mansmann, Carol Los (Pennsylvania)

McKee, Theodore Alexander (Pennsylvania)

Judge(s)

Alito, Samuel A. Jr. (New Jersey)

Becker, Edward Roy (Pennsylvania)

Cohill, Maurice Blanchard Jr. (Pennsylvania)

Cowen, Robert E. (New Jersey)

Gibbons, John Joseph (Pennsylvania)

Greenberg, Morton Ira (New Jersey)

Higginbotham, Aloyisus Leon Jr. (Pennsylvania)

Lewis, Timothy K. (Pennsylvania)

Mansmann, Carol Los (Pennsylvania)

McKee, Theodore Alexander (Pennsylvania)

Nygaard, Richard Lowell (Pennsylvania)

Papadakos, Nicholas P. (Pennsylvania)

Pollak, Louis Heilprin (Pennsylvania)

Rosenn, Max (Pennsylvania)

Roth, Jane Richards (Delaware)

Scirica, Anthony Joseph (Pennsylvania)

Sloviter, Dolores Korman (Pennsylvania)

Stapleton, Walter King (Delaware)

Van Dusen, Francis Lund (Pennsylvania)

Attorneys(s) for Plaintiff

Driscoll, Donald (Pennsylvania)

Feinstein, Edward J. (Pennsylvania)

Greenblatt, Mark B. (Pennsylvania)

Krakoff, Jere (District of Columbia)

O'Brien, Timothy P. (Pennsylvania)

Pushinsky, Jon (Pennsylvania)

Attorneys(s) for Defendant

Arch, John G. (Pennsylvania)

Biondo, Dennis R. (Pennsylvania)

Diamantopulos, George C. (Pennsylvania)

Dodaro, James J. (Pennsylvania)

Filipi, Francis R. (Pennsylvania)

Halloran, Thomas F. (Pennsylvania)

Jaffurs, Alexander J. (Pennsylvania)

Knorr, John G. III (Pennsylvania)

Koons, Calvin R. (Pennsylvania)

Liebenguth, Caroline (Pennsylvania)

McLean, James H. (Pennsylvania)

Norton, Lynette (Pennsylvania)

Nychis, Peter G. (Pennsylvania)

Pawol, Timothy W. (Pennsylvania)

Preate, Ernest D. Jr. (Pennsylvania)

Documents in the Clearinghouse

Document

2:75-cv-00412

2:76-cv-00743

Opinion

Owens-El v. Robinson

442 F.Supp. 1368

Jan. 4, 1978

Jan. 4, 1978

Order/Opinion

2:75-cv-00412

2:76-cv-00743

Opinion, Supplemental Findings of Fact and Final Order

Owen-El v. Robinson

457 F.Supp. 984

Oct. 11, 1978

Oct. 11, 1978

Order/Opinion

78-02621

Opinion of the Court

Inmates of the Allegheny County Jail v. Pierce

U. S. Court of Appeals for the Third Circuit

612 F.2d 754

Dec. 28, 1979

Dec. 28, 1979

Order/Opinion

2:76-cv-00743

Opinion and Order

Inmates of the Allegheny County Jail v. Pierce

487 F.Supp. 638

April 17, 1980

April 17, 1980

Order/Opinion

2:75-cv-00412

Memorandum Opinion

Owen-El v. Robinson

498 F.Supp. 877

Oct. 16, 1980

Oct. 16, 1980

Order/Opinion

80-02637

Opinion of the Court

Owen-El v. Robinson

U. S. Court of Appeals for the Third Circuit

694 F.2d 941

Dec. 9, 1982

Dec. 9, 1982

Order/Opinion

2:76-cv-00743

Opinion

Inmates of the Allegheny County Jail v. Wecht

565 F.Supp. 1278

May 25, 1983

May 25, 1983

Order/Opinion

2:76-cv-00743

Memorandum Opinion

Inmates of the Allegheny County Jail v. Wecht

573 F.Supp. 454

Oct. 20, 1983

Oct. 20, 1983

Order/Opinion

84-03024

84-03191

Opinion of the Court

Inmates of the Allegheny County Jail v. Wecht

U. S. Court of Appeals for the Third Circuit

754 F.2d 120

Jan. 29, 1985

Jan. 29, 1985

Order/Opinion

2:76-cv-00743

Reported Opinion

Inmates of the Allegheny County Jail v. Wecht

612 F.Supp. 874

June 26, 1985

June 26, 1985

Order/Opinion

Resources

Docket

Last updated Aug. 15, 2022, 3:17 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Pennsylvania

Case Type(s):

Jail Conditions

Key Dates

Filing Date: April 4, 1975

Closing Date: 1996

Case Ongoing: No

Plaintiffs

Plaintiff Description:

All inmates of the Allegheny County Jail.

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Allegheny County Jail (Allegheny), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Due Process: Substantive Due Process

Availably Documents:

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: 1978 - 1996

Issues

General:

Access to lawyers or judicial system

Mail

Phone

Sanitation / living conditions

Totality of conditions

Crowding:

Crowding / caseload

Pre-PLRA Population Cap

Affected Gender:

Male

Medical/Mental Health:

Mental health care, general

Type of Facility:

Government-run