Case: Lareau v. Manson

2:78-00145 | U.S. District Court for the District of Connecticut

Filed Date: March 21, 1978

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Case Summary

In 1980 inmates of the Hartford Community Correctional Center ("HCCC") filed separate lawsuits under 42 U.S.C. § 1983 in the United States District Court for the District of Connecticut against the Warden of the prison and the Commissioner of Corrections for overcrowding, inadequacies in health care, sanitation, food, heating, recreation, counseling services and safety. Plaintiffs were represented by various legal services organizations in Connecticut. The plaintiffs' actions were consolidate…

In 1980 inmates of the Hartford Community Correctional Center ("HCCC") filed separate lawsuits under 42 U.S.C. § 1983 in the United States District Court for the District of Connecticut against the Warden of the prison and the Commissioner of Corrections for overcrowding, inadequacies in health care, sanitation, food, heating, recreation, counseling services and safety. Plaintiffs were represented by various legal services organizations in Connecticut. The plaintiffs' actions were consolidated into one class action. The Court (Judge Jose A. Cabranes) found for the plaintiffs on the issue of overcrowding but in doing so, it held that the overcrowding was the root of most of the other complaints and refused to find additional specific violations. The Court ordered specific remedies to deal with the overcrowding and the ancillary issues related to it, and defendants appealed. Lareau v. Manson, 507 F.Supp. 1177 (D.CT. 1980).

On June 1, 1981, the United States Court of Appeals for the Second Circuit affirmed the Court's decision in the following ways: (1) the prison violated due process rights of pretrial detainees by confining them and other inmates in overcrowded conditions not reasonably related to a legitimate goal to justify forcing them to endure genuine privation and hardship over an extended period of time; and (2) subjecting sentenced inmates to combination of double-bunking and overcrowded dayrooms violated their Eighth Amendment rights when imposed for a period of time in excess of 30 days. The Appellate Court modified and remanded the Court's holding on a strict design capacity population cap and an absolute prohibition of any double bunking. The Court found these provisions unfeasible. It instructed that the more flexible and feasible alternative was to limit the maximum duration of the inmates' confinement in the double cells rather than prohibit double bunking altogether and it remanded the provision back for appropriate modification. Lareau v. Manson, 651 F.2d 96 (2nd Cir. 1981).

No further information is available.

Summary Authors

Rebecca Bloch (4/21/2006)

People


Judge(s)

Cabranes, José Alberto (Connecticut)

Friendly, Henry Jacob (New York)

Kearse, Amalya Lyle (New York)

Mansfield, Walter Roe (New York)

Attorneys(s) for Plaintiff

Blue, Jon C. (Connecticut)

Greene, James W. Jr. (Connecticut)

Stone, Martha (Connecticut)

Attorneys(s) for Defendant

Ajello, Carl R. (Connecticut)

Bezanson, Lee (Connecticut)

O'Neill, Stephen J. (Connecticut)

Judge(s)

Cabranes, José Alberto (Connecticut)

Friendly, Henry Jacob (New York)

Kearse, Amalya Lyle (New York)

Mansfield, Walter Roe (New York)

Attorneys(s) for Plaintiff

Blue, Jon C. (Connecticut)

Greene, James W. Jr. (Connecticut)

Stone, Martha (Connecticut)

Attorneys(s) for Defendant

Ajello, Carl R. (Connecticut)

Bezanson, Lee (Connecticut)

O'Neill, Stephen J. (Connecticut)

Documents in the Clearinghouse

Document

2:78-00145

78-00199

Memorandum of Decision

507 F.Supp. 1177, 1980 U.S.Dist.LEXIS 16600

Dec. 29, 1980

Dec. 29, 1980

Order/Opinion

81-02012

Reported Opinion

U. S. Court of Appeals for the Second Circuit

651 F.2d 96, 1981 U.S.App.LEXIS 12711

June 1, 1981

June 1, 1981

Order/Opinion

Resources

Docket

Last updated Aug. 13, 2022, 3:16 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Connecticut

Case Type(s):

Prison Conditions

Key Dates

Filing Date: March 21, 1978

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

inmates of the Hartford Community Correctional Center

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Hartford Community Correctional Center (Hartford), State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1980 - None

Issues

General:

Counseling

Food service / nutrition / hydration

Recreation / Exercise

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Totality of conditions

Crowding:

Crowding / caseload

Pre-PLRA Population Cap

Medical/Mental Health:

Medical care, general

Type of Facility:

Government-run