Case: Hudler v. Duffy

77-404148 | California state trial court

Filed Date: 1977

Closed Date: May 5, 1995

Clearinghouse coding complete

Case Summary

In two consolidated cases, San Diego County inmates brought suit in state court challenging overcrowding conditions at five detention facilities: the Las Colinas Detention Facility for Women, El Cajon, South Bay, Vista and Descanso detention facilities. Hudler v. Duffy was filed in 1977 and Armstrong v. Board of Supervisors was filed in 1987. While we were unable to obtain the written opinion, the case is discussed in Wayne Welsh, Counties in Court: Jail Overcrowding and Court-Ordered Reform (…

In two consolidated cases, San Diego County inmates brought suit in state court challenging overcrowding conditions at five detention facilities: the Las Colinas Detention Facility for Women, El Cajon, South Bay, Vista and Descanso detention facilities. Hudler v. Duffy was filed in 1977 and Armstrong v. Board of Supervisors was filed in 1987.

While we were unable to obtain the written opinion, the case is discussed in Wayne Welsh, Counties in Court: Jail Overcrowding and Court-Ordered Reform (1995). Welsh reports that the California Superior Court (Judge James L. Facht) issued a ruling in 1980, noting major problems with overcrowding and inadequate staffing in San Diego County and calling the jail an "architectural nightmare." Orders were made to improve staffing and reduce overcrowding. The case gave rise to a consent decree that imposed a cap on the population at the jail and gave the Superior Court jurisdiction to monitor the inmate population. Armstrong v. Bd. of Supervisors, No. 588349 (Super. Ct. San Diego County 1987), consolidated with Hudler v. Duffy, No. 404148 (Super. Ct. San Diego County 1977) (Judge Arthur W. Jones). The Superior Court of San Diego County retained jurisdiction to monitor and enforce the agreement.

Apparently in this or another ruling, on August 14, 1980, the Superior Court also held that the County's policy of strip searching all detainees was lawful. See Ward v. Cnty. of San Diego, 791 F.2d 1329 (9th Cir. 1986).

On August 29, 1994, the San Diego Superior Court found San Diego County officials in contempt of the consent degree by failing to provide adequate resources for the sheriff necessary to comply with the population cap in the decree, and imposed fines for willfully disobeying the terms of the consent decree. (A search did not find further information on this order.)

Members of the San Diego County Board of Supervisors sought a writ asking the Superior Court to vacate its order finding them in contempt of court. The Board alleged that the court exceeded its jurisdiction by interpreting the terms of the underlying consent decree and by usurping legislative discretion over the allocation of public funds.

On April 14, 1995, the California Court of Appeal (Judge Richard D. Huffman) vacated the contempt order as to the Board of Supervisors and directed that fines it paid be returned to to the Board. Bd. of Supervisors v. Superior Court, 33 Cal. App. 4th 1724 (1995). In particular, the appellate court found that there was not substantial evidence that the board willfully disobeyed the consent decree. Noting that the Board of Supervisors was charged with providing the sheriff with food, clothing and bedding for prisoners, it concluded that the Board had not been given direct authority over jail operations, such as the day-to-day compliance with the population cap.

A petition for rehearing was denied on May 5, 1995. We have no further information.

Summary Authors

Denise Lieberman (11/7/2005)

People


Judge(s)

Huffman, Richard D. (California)

Attorneys(s) for Plaintiff

Knoll, Gregory E. (California)

Landon, Alexander L. (California)

Levitan, Anson B. (New Mexico)

Scott, Charles (California)

Other Attorney(s)

Active

Active

Active

Active

Judge(s)

Huffman, Richard D. (California)

Attorneys(s) for Plaintiff

Knoll, Gregory E. (California)

Landon, Alexander L. (California)

Levitan, Anson B. (New Mexico)

Scott, Charles (California)

Other Attorney(s)

Bardsley, Diane (California)

Budd, Jordan C. (California)

Harmon, Lloyd (California)

Northrup, Nathan (California)

Documents in the Clearinghouse

Document

Reported Opinion

Board of Supervisors v. Superior Court

California state appellate court

33 Cal.App.4th 1724, 1995 Cal.App.LEXIS 352

April 14, 1995 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

Key Dates

Filing Date: 1977

Closing Date: May 5, 1995

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Inmates of San Diego County complaining of crowded cells.

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

San Diego County (San Diego), County

Case Details

Causes of Action:

Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Unknown

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1988 - None

Issues

General:

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Crowding:

Crowding / caseload

Pre-PLRA Population Cap

Type of Facility:

Government-run