Case: French v. Miller

1:75-cv-00677 | U.S. District Court for the Southern District of Indiana

Filed Date: Nov. 21, 1975

Closed Date: 2002

Clearinghouse coding complete

Case Summary

On November 21, 1975, four inmates confined at the Indiana Reformatory in Pendleton, Indiana filed a pro se lawsuit pursuant to 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Indiana, challenging their conditions of confinement. The initial pro se complaint was dismissed by the Court with leave granted to re-file the case. On May 13, 1976, attorneys for the Legal Services Organization of Indianapolis, Indiana filed an amended class action complaint, alleging poor liv…

On November 21, 1975, four inmates confined at the Indiana Reformatory in Pendleton, Indiana filed a pro se lawsuit pursuant to 42 U.S.C. § 1983 in the U.S. District Court for the Southern District of Indiana, challenging their conditions of confinement. The initial pro se complaint was dismissed by the Court with leave granted to re-file the case. On May 13, 1976, attorneys for the Legal Services Organization of Indianapolis, Indiana filed an amended class action complaint, alleging poor living conditions, inadequate medical care, lack of safety and security, bad food services, inadequate educational opportunities, insufficient access to the courts, and an arbitrary system of prison discipline at the Reformatory. The case was certified as a class action on December 20, 1977.

The U.S. Department of Justice (DOJ) was granted leave to participate as amicus curiae on March 10, 1978.

Trial began on July 5, 1978 and ended on August 14, 1978. It was reopened for further proceedings between March 1-5, 1982. The District Court (Judge S. Hugh Dillin) found for the plaintiff class and ordered changes to the operation of the Reformatory in the areas of: inmate population, medical care, food, sanitation, recreational opportunities, security, mental health programs, and fire safety. French v. Owens, 538 F.Supp. 910 (S.D. Ind. 1982). Defendants appealed.

The Court of Appeals for the Seventh Circuit remanded to determine whether the injunctive relief ordered by the District Court was based on state law or the Eighth Amendment, in light of the recent Supreme Court decision Pennhurst State School and Hospital v. Haldemzan, 465 US. 89, 104 S.Ct. 900, 79 L.Ed.2d 67 (1984), which held that federal courts lacked jurisdiction over claims for injunctive relief against state officials based upon state law.

On remand, the District Court found that most of the Reformatory conditions violated the Eighth Amendment as well as state law. The Court issued an amended order in light of the Pennhurst case. The amended order also accounted for improvements that had been made at the Reformatory since the Court's original order. The defendants appealed again.

The Court of Appeals (Judge Richard Dickson Cudahy) affirmed in part, holding that conditions in the state prison such as overcrowding, double celling, unwholesome food, medical neglect, and threats to inmates' safety violated the Eighth Amendment. The Court of Appeals also vacated and remanded the judgment as it pertained to exercise, protective custody, and fire and occupational safety. French v. Owens, 777 F.2d 1250 (7th Cir. 1986).

In 1998, the defendants petitioned to terminate the injunction pursuant to the Prison Litigation Reform Act [PLRA]. The District Court (Judge S. Hugh Dillin) granted a preliminary injunction against the enforcement of the PLRA's automatic stay provision. The defendants appealed. The Court of Appeals (Judge Diane P. Wood) affirmed, holding that the automatic stay provision of the PLRA, codified at 18 U.S.C. § 3626(e)(2), was unconstitutional. French v. Duckworth, 178 F.3d 437 (7th Cir. 1999).

The Supreme Court of the United States granted certiorari and reversed and remanded, holding that the automatic stay provision of the PLRA did not violate separation of powers principles. Miller v. French 530 U.S. 327 (2000).

Following remand, the District Court's Decree Order was terminated on October 23, 2000 pursuant to the PLRA. According to information received from the state AGs office, upon its termination, the parties entered into a Private Settlement Agreement as to the continued operation of the Reformatory, which had been renamed as the Pendleton Correctional Facility. The Agreement expired by its own terms on October 23, 2002. No subsequent decrees or agreements were entered and the case remained closed as of the date of this summary.

Note that there was no PACER docket available for this case.

Summary Authors

Rebekah Henn Sullivan (3/6/2007)

People


Judge(s)

Breyer, Stephen Gerald (District of Columbia)

Cudahy, Richard Dickson (Illinois)

Dillin, Samuel Hugh (Indiana)

Eschbach, Jesse Ernest (Indiana)

Flaum, Joel Martin (Illinois)

Ginsburg, Ruth Bader (District of Columbia)

Kennedy, Anthony McLeod (District of Columbia)

Morton, Leland Clure (Tennessee)

O'Connor, Sandra Day (District of Columbia)

Rehnquist, William Hubbs (District of Columbia)

Judge(s)

Breyer, Stephen Gerald (District of Columbia)

Cudahy, Richard Dickson (Illinois)

Dillin, Samuel Hugh (Indiana)

Eschbach, Jesse Ernest (Indiana)

Flaum, Joel Martin (Illinois)

Ginsburg, Ruth Bader (District of Columbia)

Kennedy, Anthony McLeod (District of Columbia)

Morton, Leland Clure (Tennessee)

O'Connor, Sandra Day (District of Columbia)

Rehnquist, William Hubbs (District of Columbia)

Rovner, Ilana Kara Diamond (Illinois)

Scalia, Antonin (District of Columbia)

Souter, David Hackett (District of Columbia)

Stevens, John Paul (District of Columbia)

Thomas, Seth (Iowa)

Wood, Diane Pamela (Illinois)

Attorneys(s) for Plaintiff

Barker, Sarah Evans (Indiana)

Bickham, Harold R. (Indiana)

Falk, Kenneth J. (Indiana)

Kashani, Hamid R. (Indiana)

Lundberg, Donald R. (Indiana)

Ory, Charles (District of Columbia)

Whinston, Stephen A. (District of Columbia)

Attorneys(s) for Defendant

Arthur, David A. (Indiana)

Johnson, Carl L. (Indiana)

Laramore, Jon B. (Indiana)

Pearson, Linley E. (Indiana)

Underwood, Barbara D. (District of Columbia)

Other Attorney(s)

Schlanger, Margo (District of Columbia)

Documents in the Clearinghouse

Document

Order

French v. Owens & U.S.

March 5, 1982 Order/Opinion

Memorandum of Decision

French v. Owens

538 F.Supp. 910

May 7, 1982 Order/Opinion

Reported Opinion

French v. Owens

U. S. Court of Appeals for the Seventh Circuit

777 F.2d 1250

Feb. 12, 1986 Order/Opinion

Memorandum Decision

Owens v. French

Supreme Court of the United States

479 U.S. 817, 107 S.Ct. 77, 93 L.Ed.2d 32

Oct. 6, 1986 Order/Opinion

Opinion

French v. Duckworth

U. S. Court of Appeals for the Seventh Circuit

178 F.3d 437

May 6, 1999 Order/Opinion

Memorandum

Duckworth v. French

Supreme Court of the United States

528 U.S. 1045, 120 S.Ct. 528, 145 L.Ed.2d 481

Nov. 6, 1999 Order/Opinion

Memorandum Decision

Miller v. French

Supreme Court of the United States

530 U.S. 327, 120 S.Ct. 2246, 147 L.Ed.2d 326

June 19, 2000 Order/Opinion

Order

U. S. Court of Appeals for the Seventh Circuit

234 F.3d 1273, 2000 WL 1180299

Aug. 17, 2000 Order/Opinion

Resources

Title Description External URL

Miller v. French

Oyez

In 1975, inmates at the Pendleton Correctional Facility filed a class action lawsuit, which ultimately led the District Court to issue an injunction to remedy Eighth Amendment violations regarding co… June 19, 2000 https://www.oyez.org/cases/1999/99-224

The Oyez Project, Miller v. French, 530 U.S. 327 (2000).

Oyez Project

Information about the Supreme Court litigation in this case, including audio recordings of the oral argument and opinion announcement, and the written opinion. June 19, 2000 http://www.oyez.org/cases/1990-1999/1999/1999_99_224/

Docket

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

Docket sheet not available via the Clearinghouse.

State / Territory: Indiana

Case Type(s):

Prison Conditions

Key Dates

Filing Date: Nov. 21, 1975

Closing Date: 2002

Case Ongoing: No

Plaintiffs

Plaintiff Description:

All inmates confined, or who in the future would be confined, at the Indiana Reformatory in Pendleton, Indiana (later known as the Pendleton Correctional Facility).

Public Interest Lawyer: Yes

Filed Pro Se: Yes

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Pendleton Correctional Facility (Pendleton), State

Indiana Reformatory (Pendleton), State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Availably Documents:

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1975 - 2002

Content of Injunction:

Preliminary relief granted

Issues

General:

Access to lawyers or judicial system

Disciplinary procedures

Education

Fire safety

Food service / nutrition / hydration

Recreation / Exercise

Sanitation / living conditions

Staff (number, training, qualifications, wages)

Totality of conditions

Crowding:

Crowding / caseload

Medical/Mental Health:

Medical care, unspecified

Mental health care, general

Type of Facility:

Government-run