Case: Anderson v. Redman

In 1976, inmates at the Delaware Correctional Center, represented by counsel from the community Legal Aid Society, filed a section 1983 class action suit in the U.S. District Court for the District of Delaware against prison officials. The original complaint, docket 76-202, was superseded by an identical complaint filed later that year with the docket 76-364. (The multiple filings were a result of the uncertainty regarding the status of the three-judge court act, 28 USC section 2281. After the act was repealed by Congress all parties agreed to the filing of the new complaint.) Plaintiffs alleged unconstitutional overcrowding as well as violation of various state laws regarding housing of inmates, and sought injunctive relief.

After a seven day trial, Judge Murray Schwartz granted plaintiffs' motion for immediate relief from overcrowding in the receiving section of the facility, holding conditions there to be in violation of the Eighth Amendment. But his opinion dated February 16, 1977, Judge Schwartz declined to rule more permanently on the federal constitutional issue and instead found that the general overcrowding of the facility was in violation of state statutory laws. The court ordered the defendants to remedy the problem by reducing inmate population, and set out eight pages of what it termed ""suggestions"" rather than ""mandatory requirements."" Anderson v. Redman, 428 F. Supp. 1105, 1128 (D. Del. 1977). Plaintiffs sought and were awarded attorneys' fees. 474 F. Supp. 511, 524 (D. Del. 1979).

In June 1979, the Delaware legislature passed a law (H.B. 495) specifically written to undercut the state law premise of the 1977 order. Defendants sought to vacate the earlier order while plaintiffs wanted the new state law declared unconstitutional under the Delaware state constitution. On November 28, 1979, the court denied the defendants’ motion to vacate. Judge Schwartz abstained from entertaining the state constitutional challenge and stayed his 1977 order until the constitutionality of the state law could be determined in the Delaware state courts and ordered the plaintiffs to litigate in Delaware state court. Anderson v. Redman, 480 F. Supp. 830, 833 (D. Del. 1979). 

In accordance with the order to litigate in State court, a class action was filed in the Court
of Chancery of Delaware, New Castle County, in March 1980. Dickerson v. Castle. 1991 WL 208467 (Del. Ch. 1991) ("Dickerson I").  

The parties reached a settlement agreement and the Court of Chancery entered an order approving the agreement on November 28, 1988. The agreement went beyond the original complaint, covering conditions at all four major prisons operated by the Delaware Department of Correction. The Dickerson class action was dismissed on September 7, 1995 with each party to bear its own costs. 

In 1984, The U.S. Supreme Court held that federal courts lack jurisdiction to enjoin compliance with state statutes. Pennhurst State School v. Halderman, 465 U.S. 89 (1984).

No further action took place on this case until September 22, 2014, when a plaintiff filed an instant motion to enforce judgment. The court dismissed this motion after finding that the defendants were likely not in violation, the individual plaintiff did not have standing to sue, and the Dickerson settlement ended this case. 

This case remains closed.