Case: Inmates of the Maine State Prison v. Zitnay

2:78-cv-00090 | U.S. District Court for the District of Maine

Filed Date: May 5, 1978

Closed Date: July 23, 1984

Clearinghouse coding complete

Case Summary

This case represents three consolidated class actions challenging conditions and policies at the Maine State Prison (MSP), Maine's only maximum security correctional facility for men. Represented by the ACLU National Prison Project and Pine Tree Legal Assistance with the help of private counsel, inmates of the Maine State Prison brought the initial civil rights suit, No. 78-90 in federal court pursuant to 42 U.S.C. Sec. 1983 on May 5, 1978. This case was brought on behalf of all MSP inmates who…

This case represents three consolidated class actions challenging conditions and policies at the Maine State Prison (MSP), Maine's only maximum security correctional facility for men. Represented by the ACLU National Prison Project and Pine Tree Legal Assistance with the help of private counsel, inmates of the Maine State Prison brought the initial civil rights suit, No. 78-90 in federal court pursuant to 42 U.S.C. Sec. 1983 on May 5, 1978. This case was brought on behalf of all MSP inmates who had been or might be confined in administrative segregation. The case was subsequently consolidated with two related class actions filed by inmates at MSP: Maine State Prison et al v. Mental Health & Corr., No. 79-8, brought on behalf of all inmates in protective custody, and Lovell et al v. Corrections et al., No. 79-76, brought on behalf of all inmates in the general population. All three cases also challenged use of so-called ""restraint cells"" - also known as ""the hole"" by inmates - in the prison's segregation unit. Suit was brought against the Governor of Maine, the Commissioner of the Department of Corrections and the Warden at MSP.

In the first case, inmates challenged poor conditions in administrative segregation as well as the process for assigning inmates to administrative segregation, alleging that it not only violated the U.S. Constitution and state law, but also was in violation of a 1973 consent decree in Inmates v. Mullaney (No. 11-187) (D.Me. 1973), PC-ME-003. The other cases challenged conditions in protective custody and in the general population, alleging that they violated the 8th Amendment's ban on cruel and unusual punishment.

Following initial evidentiary hearings, a new warden was appointed to the prison, who made substantial improvements in the prison's programs, and the record was re-opened. However, further negotiations failed to resolve the cases, and comprehensive briefs were filed and oral arguments held in October 1982.

On June 22, 1983, Judge Edward Gignoux issued an opinion and order in the three cases, finding the claims related to administrative segregation meritorious, but rejecting the other challenges. Lovell v. Brennan, 566 F.Supp. 672 (D.Me. 1983), which was affirmed by the 1st Circuit Court of Appeals. Lovell v. Brennan, 728 F.2d 560 (1st Cir. 1984).

While finding that overall conditions of confinement did not violate inmates' rights, in his ruling, Judge Gignoux concluded that the procedures for assigning inmates to administrative segregation violated the terms of the 1973 consent decree and that the prison's use of restraint cells was ""so inhumane"" that it violated the 8th and 14th Amendments (the small, windowless cells had no internal lighting or heat and were completely barren, except for a hole in the floor which served as a toilet, which could not be flushed from inside the cell). The court issued an order barring further violations in those areas. The Court, dismissing the remaining claims, found that the other conditions of confinement the inmates complained of had improved substantially since the filing of the lawsuit and did not currently violate the constitution or the consent decree. Lovell v. Brennan, 566 F.Supp at 677. The court noted, however, that the prison conditions improved only because of the lawsuit and only to the minimum extent required by law.

Subsequently, the attorneys for the inmates in all three cases sought attorneys fees. The Court, in an opinion by Judge Gignoux, concluded that because the plaintiffs had succeeded on the major claims of their case, that they were considered ""prevailing parties"" and should be awarded attorneys fees. Inmates of the Maine State Prison v. Zitnay, 590 F.Supp. 979 (D.Me. 1984).

The partial docket sheet available on PACER includes only the parties' names.

Summary Authors

Denise Lieberman (10/16/2005)

People


Judge(s)

Bownes, Hugh Henry (New Hampshire)

Breyer, Stephen Gerald (District of Columbia)

Coffin, Frank Morey (Maine)

Gignoux, Edward Thaxter (Maine)

Attorneys(s) for Plaintiff

Bronstein, Alvin J. (District of Columbia)

Davidson, R. James (Maine)

Geores, Martha E. (Maine)

Klein, Edward (Maine)

Thibeault, Paul G. (Maine)

Woodruff, Neville (Maine)

Judge(s)

Bownes, Hugh Henry (New Hampshire)

Breyer, Stephen Gerald (District of Columbia)

Coffin, Frank Morey (Maine)

Gignoux, Edward Thaxter (Maine)

Attorneys(s) for Plaintiff

Bronstein, Alvin J. (District of Columbia)

Davidson, R. James (Maine)

Geores, Martha E. (Maine)

Klein, Edward (Maine)

Thibeault, Paul G. (Maine)

Woodruff, Neville (Maine)

Attorneys(s) for Defendant

Laubenstein, William H. III (Maine)

Ogilvie, Gail (Maine)

Tierney, James E. (Maine)

Documents in the Clearinghouse

Document

79-cv-00008

Docket (PACER)

Maine State Prison v. Mental Health & Corr.

June 22, 1983

June 22, 1983

Docket

2:79-cv-00076

Docket [PACER]

June 22, 1983

June 22, 1983

Docket

2:78-cv-00090

Docket (PACER)

Inmates for the Maine State Prison v. Corrections

June 22, 1983

June 22, 1983

Docket

2:78-cv-00090

79-cv-00008

2:79-cv-00076

Opinion and Order of the Court

Lovell v. Brennan

566 F.Supp. 672, 1983 U.S.Dist.LEXIS 16057

June 22, 1983

June 22, 1983

Order/Opinion

83-01572

Opinion

Lovell v. Brennan

U. S. Court of Appeals for the First Circuit

728 F.2d 560, 1984 U.S.App.LEXIS 24967

Feb. 29, 1984

Feb. 29, 1984

Order/Opinion

2:78-cv-00090

Memorandum Opinion of and Order of the Court

590 F.Supp. 979, 1984 U.S.Dist.LEXIS 14742

July 23, 1984

July 23, 1984

Order/Opinion

Resources

Docket

Last updated Aug. 12, 2022, 1:34 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Maine

Case Type(s):

Prison Conditions

Key Dates

Filing Date: May 5, 1978

Closing Date: July 23, 1984

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

prisoners in administrative segregation at the Maine State Prison

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Maine Department of Corrections (Thomaston), State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Availably Documents:

Trial Court Docket

Any published opinion

Outcome

Prevailing Party: Mixed

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Order Duration: 1983 - None

Issues

General:

Administrative segregation

Classification / placement

Disciplinary segregation

Protective custody

Sanitation / living conditions

Totality of conditions

Affected Gender:

Male

Type of Facility:

Government-run