Case: Crowe v. Jones

1:96-cv-00214 | U.S. District Court for the Southern District of Alabama

Filed Date: March 6, 1996

Closed Date: 1996

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Case Summary

On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were in violation of a consent decree issued in an earlier case, Pugh v. Locke, 406 F. Supp. 318 (M.D. Ala. 1976) (PC-AL-010), which mandated that there "shall be space available for inmates to engage in …

On March 6, 1996, eight inmates filed a Section 1983 lawsuit against the Alabama Department of Corrections alleging Eighth Amendment violations for restrictions on the inmates' access to and use of the hobby shop at Holman Correctional Facility. Plaintiffs also contended that the restrictions were in violation of a consent decree issued in an earlier case, Pugh v. Locke, 406 F. Supp. 318 (M.D. Ala. 1976) (PC-AL-010), which mandated that there "shall be space available for inmates to engage in hobbies." Pugh, 406 F. Supp. at 335. The inmates were granted leave to proceed in forma pauperis, and each inmate represented himself pro se.

The inmates alleged that the "spirit and intent of the consent decree" was being violated in several ways by defendants. For example, the inmates alleged that defendants limited the amount of supplies inmates could order each month, limited the amount of finished crafts that inmates could mail out of the facility and to whom inmates could mail such crafts, limited the number of inmates who were allowed access to the hobby shop in a selective and discriminatory manner, and often closed the shop for up to two weeks as group punishment for incidents unrelated to the hobby shop. Restricted access to the hobby shop, according to the inmates, was a violation of the Eight Amendment because it restricted the inmates' means to make an income, and because the hobby shop was essential in order to maintain a safe environment in the overcrowded prison.

The U.S. District Court for the Southern District of Alabama found that the inmates had not made a successful claim, because they could not show that they had been deprived of a constitutional right. Specifically, the court found that: 1) there existed no constitutionally protected right for an inmate to have access to a hobby shop; 2) the claim that the denied access was in violation of the Pugh consent decree was not a violation of a federal right because the consent decree was no longer in effect following Newman v. Alabama, No. 3501-N, 1988 U.S. Dist. LEXIS 18633, (M.D. Ala. Dec. 28, 1998)(PC-AL-017) and because access to a hobby shop was not a constitutionally protected liberty interest and 3) denied or restricted access to a hobby shop is not a deprivation of a single human need, and therefore is not an Eight Amendment violation. The case was dismissed without prejudice as frivolous, prior to service of process (Judge Richard W. Vollmer, Jr. signed the Report and Recommendations issued by Mag. Judge William H. Steele on May 13, 1996). Crowe v. Jones, 96-0214, 1996 U.S. Dist. LEXIS 8566 (S.D. Ala. May 13, 1996).

Summary Authors

Megan Raynor (1/23/2006)

People


Judge(s)

Steele, William H. (Alabama)

Vollmer, Richard W. Jr. (Alabama)

Judge(s)

Steele, William H. (Alabama)

Vollmer, Richard W. Jr. (Alabama)

Documents in the Clearinghouse

Document

Docket (PACER)

June 4, 1996 Docket
11

Order

1996 U.S.Dist.LEXIS 8566

May 13, 1996 Order/Opinion

Docket

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

ECF Number Description Date Link
1

1983 COMPLAINT filed; FILING FEE $ ifp (mca) (Entered: 03/08/1996)

March 6, 1996
2

MOTION by Billy W. Crowe to Proceed in Forma Pauperis ; ref. to M/Steele 3/8/96 (mca) (Entered: 03/08/1996)

March 6, 1996
3

MOTION by Larry Childs to Proceed in Forma Pauperis ;ref. to M/Steele 3/11/96 (mca) (Entered: 03/11/1996)

March 6, 1996
4

MOTION by David Beech to Proceed in Forma Pauperis ;ref. to M/STeele (mca) (Entered: 03/11/1996)

March 6, 1996
5

MOTION by Michael Nelson to Proceed in Forma Pauperis ; ref. to M/Steele (mca) (Entered: 03/11/1996)

March 6, 1996
6

MOTION by James Dillard to Proceed in Forma Pauperis ;ref. to M/STeele (mca) (Entered: 03/11/1996)

March 6, 1996
7

MOTION by Richard Frazier to Proceed in Forma Pauperis ; ref. to M/Steele (mca) (Entered: 03/11/1996)

March 6, 1996
8

MOTION by William Gates to Proceed in Forma Pauperis ;ref. to M/Steele (mca) (Entered: 03/11/1996)

March 6, 1996
9

MOTION by Roy Harvell to Proceed in Forma Pauperis ;ref. to M/Steele (mca) (Entered: 03/11/1996)

March 6, 1996

CASE reassigned to Judge Richard W. Vollmer Jr. (mca) (Entered: 03/15/1996)

March 15, 1996
10

REPORT AND RECOMMENDATIONS recommending that case be dismissed w/o prejudice as frivolous, prior to service of process; Objections to R and R due by 5/30/96 ( signed by Mag. Judge William H. Steele ) copies mailed (srr) (Entered: 05/13/1996)

May 13, 1996
11

ORDER granting [2-1] Crowe's motion to Proceed in Forma Pauperis, granting [9-1] Harvell's motion to Proceed in Forma Pauperis, granting [8-1] Gates' motion to Proceed in Forma Pauperis, granting [7-1] Frazier's motion to Proceed in Forma Pauperis, granting [6-1] Dillard's motion to Proceed in Forma Pauperis, granting [5-1] Nelson's motion to Proceed in Forma Pauperis, granting [4-1] Beech's motion to Proceed in Forma Pauperis, granting [3-1] Childs' motion to Proceed in Forma Pauperis; Clerk is directed to w/hold service pending disposition of R/R ( signed by Mag. Judge William H. Steele ) copies mailed (srr) Modified on 05/13/1996 (Entered: 05/13/1996)

May 13, 1996
12

ORDER ADOPTING [10-1] REPORT AND RECOMMENDATIONS ( signed by Judge Richard W. Vollmer Jr. ) copies mailed (srr) (Entered: 06/04/1996)

June 4, 1996
13

JUDGMENT that this action is DISMISSED w/o prejudice as frivolous; no costs taxed ( signed by Judge Richard W. Vollmer Jr. ); J/E 5216 Judgment EOD: 6/4/96 (copies mailed) (srr) (Entered: 06/04/1996)

June 4, 1996

Case closed (srr) (Entered: 06/04/1996)

June 4, 1996

State / Territory: Alabama

Case Type(s):

Prison Conditions

Key Dates

Filing Date: March 6, 1996

Closing Date: 1996

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Alabama prison inmates whose claims concern the restrictions placed on their access and use of the hobby shop at Holman Correctional Facility

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: Yes

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Alabama Department of Corrections, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Availably Documents:

Trial Court Docket

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Recreation / Exercise

Type of Facility:

Government-run