Case: Dickerson v. Castle

80-10256 | Delaware state trial court

Filed Date: March 17, 1980

Clearinghouse coding complete

Case Summary

Prisoners in the Delaware state prison system filed a class action lawsuit in March 1980 in the Delaware Court of Chancery in New Castle County alleging that overcrowding at the prison in Smyrna violated article I, §11 of the Delaware Constitution which provides that ""in the construction of jails a proper regard shall be had to the health of prisoners."" The plaintiff class was represented by Community Legal Aid Society, the ACLU of Delaware and the ACLU National Prison Project. A settlement a…

Prisoners in the Delaware state prison system filed a class action lawsuit in March 1980 in the Delaware Court of Chancery in New Castle County alleging that overcrowding at the prison in Smyrna violated article I, §11 of the Delaware Constitution which provides that ""in the construction of jails a proper regard shall be had to the health of prisoners."" The plaintiff class was represented by Community Legal Aid Society, the ACLU of Delaware and the ACLU National Prison Project. A settlement agreement was entered on November 28, 1988, and the agreement's broad provisions covered many areas not originally contained in the complaint by addressing health care services, legal access, and environmental conditions as well as overcrowding. The agreement's provisions were to be applied to all four major prisons operated by the Delaware Department of Correction. Approximately one year after entry of the agreement, the plaintiffs filed a motion to show cause why the defendants should not be held in civil contempt based on alleged violations of the settlement agreement. After filing the contempt motion, the defendants, state prison officials, made significant improvements in the state prisons including improvements in ventilation systems, beginning construction of a new women's prison, and work release and pre-trial release programs to reduce overcrowding.

Because of these improvements, the Court of Chancery (Vice-Chancellor Chandler) found that the defendants were in compliance with the settlement agreement. Dickerson v. Castle, Civ.A.No. 10256, 1991 WL 208467 (Del.Ch. Oct. 15, 1991) (unpublished memorandum opinion). However, Vice-Chancellor Chandler concluded that under the Court of Chancery's inherent equitable powers, reasonable attorneys' fees to plaintiffs' counsel were to be awarded because the motion and ensuing litigation resulted in certain benefits for the plaintiff class. In subsequent litigation over the amount of attorneys' fees, the plaintiffs argued that they were entitled to the lodestar figure of $311,405. Vice-Chancellor Chandler instead held that plaintiffs' reasonable attorneys' fees were $30,000, considering the benefits obtained for the class and the causal connection of those benefits to this litigation. Dickerson v. Castle, Civ.A.No. 10256, 1992 WL 205796 (Del.Ch. Aug. 21, 1992) (unpublished memorandum opinion). The Supreme Court of Delaware affirmed the decision regarding attorneys' fees on March 2, 1993. Dickerson v. Castle, 622 A.2d 1094 (Del. 1993).

The plaintiffs filed a subsequent contempt motion which was settled by a stipulation order entered on December 15, 1992, that addressed overcrowding problems and tuberculosis control throughout the prison system and legal access at the Women's Correctional Institute. After a third contempt motion filed by the plaintiffs, Vice-Chancellor Chandler found for the defendants on all counts except for a finding that the defendants had failed to implement an adequate tuberculosis control system. Dickerson v. Castle, Civ.A.No. 10256, 1995 WL 606316 (Del.Ch. Sep. 7, 1995). Vice-Chancellor Chandler also dismissed the lawsuit and ordered that any future efforts to enforce the 1988 agreement or the 1992 stipulation must be brought as a separate contract action. No docket for this case is available on PACER because it was litigated in state court.

Summary Authors

Tom Madison (4/1/2006)

People


Judge(s)

Chandler, William B. III (Delaware)

Holland, James Buchanan (Pennsylvania)

Horsey, Henry R. (Delaware)

Veasey, E. Norman (Delaware)

Attorneys(s) for Plaintiff

Alexander, Elizabeth R. (District of Columbia)

Bronstein, Alvin J. (District of Columbia)

Castle, Ben T. (Delaware)

Himelein, Neilson C. (District of Columbia)

Lopez, Mark J. (District of Columbia)

Myers, Gary A. (Delaware)

Judge(s)

Chandler, William B. III (Delaware)

Holland, James Buchanan (Pennsylvania)

Horsey, Henry R. (Delaware)

Veasey, E. Norman (Delaware)

Attorneys(s) for Plaintiff

Alexander, Elizabeth R. (District of Columbia)

Bronstein, Alvin J. (District of Columbia)

Castle, Ben T. (Delaware)

Himelein, Neilson C. (District of Columbia)

Lopez, Mark J. (District of Columbia)

Myers, Gary A. (Delaware)

Schab, H. William Jr. (Delaware)

Attorneys(s) for Defendant

Brady, Keith (Delaware)

Capano, Thomas J. (Delaware)

Danburg, Carl C. (Delaware)

Hubbard, Richard W. (Delaware)

Oberly, Charles M. (District of Columbia)

Stabler, W. Laird (Delaware)

Welch, John K. (Delaware)

White, David A. (Delaware)

Documents in the Clearinghouse

Document

76-364

Complaint for Preliminary and Permanent Injunction and Declaratory Judgment

Dickerson v. DuPont

March 17, 1980

March 17, 1980

Complaint

76-364

Settlement Agreement (Class Action)

Dickerson v. DuPont

Nov. 21, 1988

Nov. 21, 1988

Settlement Agreement

No. 10256

Memorandum Opinion

1991 WL 208467, 1991 Del.Ch.LEXIS 157

Oct. 15, 1991

Oct. 15, 1991

Order/Opinion

80-10256

Opinion

1992 WL 205796

Aug. 21, 1992

Aug. 21, 1992

Order/Opinion

No. 10256

Stipulation for Dismissal of Second Motion for Order to Show Cause

Oct. 14, 1992

Oct. 14, 1992

Pleading / Motion / Brief

80-10256

Notice and Summary of Proposed Settlement in Class Action

Oct. 30, 1992

Oct. 30, 1992

Notice Letter

No. 10256

Order

Dec. 15, 1992

Dec. 15, 1992

Order/Opinion

92-417

Order

Delaware state supreme court

622 A.2d 1094, 1993 WL 66586, 1992 Conn.LEXIS 3707

March 2, 1993

March 2, 1993

Order/Opinion

No. 10256

Amended Complaint (Class Action)

Dickerson v. DuPont

Jan. 1, 1995

Jan. 1, 1995

Complaint

No. 10256

Stipulated Order

Dickerson v. Carper

Feb. 9, 1995

Feb. 9, 1995

Order/Opinion

Resources

Docket

Last updated Aug. 1, 2022, 3:03 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Delaware

Case Type(s):

Prison Conditions

Key Dates

Filing Date: March 17, 1980

Case Ongoing: No

Plaintiffs

Plaintiff Description:

prisoners in the Delaware State Prison System

Attorney Organizations:

ACLU National (all projects)

ACLU National Prison Project

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Delaware Department of Correction, State

Case Details

Causes of Action:

State law

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: 1988 - 1995

Issues

General:

Access to lawyers or judicial system

Sanitation / living conditions

Totality of conditions

Crowding:

Crowding / caseload

Medical/Mental Health:

Medical care, general

Type of Facility:

Government-run